PRIVACY POLICY

Last updated: April 22, 2024

 

The personal information (“information”) that you entrust to us, WhiteHaven1, is essential to our business relationship with you. We know how valuable it is and we are committed to doing everything we can to protect it.

 

That is why we adopted this Privacy Policy (“Policy”), which describes our practices regarding the protection of your information and privacy. Our goal is to be transparent with you. This Policy applies to the use and disclosure of any information collected about you and to the manner in which WhiteHaven collect such information in the course of your business relationship with them. This Policy applies for as long as we hold your information, including after the end of our business relationship.

 

Other terms and conditions go along with this Policy. In particular, this Policy is supplemented by our Cookies policy, which explains how we use cookies and other similar technologies when you visit our websites or mobile apps. In addition, some products and services have specific terms and conditions governing the processing of information. It is important to take this into account.

 

IMPORTANT! We may change this Policy from time to time. You will be notified by a notice appearing on our websites and by any other appropriate means of contacting you.

 

Our Chief Privacy Officer is accountable for the privacy practices within WhiteHaven.

Dimitri Kufedjian

dimitri.kufedjian@whitehaven.ca

514-875-9900, ext. 1022

1595 Daniel-Johnson Blvd, suite 300, Laval (QC), H7V 4C2

 

1. The collection of information
1.1. The type of information we may collect
Information to identify yourself and verify your identity
  • First and last name
  • Date of birth
  • Civil status
  • Contact information
  • Email address
  • Information from an acceptable identification document (driver’s licence, passport, Social Insurance Number*)
  • Job
  • Account numbers
  • Information we have about you as an authorized representative, director, officer or shareholder
  • User ID
  • Signatures
  • Account information
Financial information to analyze your needs and verify your eligibility for products and services, and information about your operations
  • Income, salary and balances
  • Products and investments and their terms and conditions (e.g., term, repayment frequency, limits, rates, expiration, etc.)
  • Credit score
  • Professional and financial background
  • History of the transactions and interactions in your accounts
  • Investment instructions
  • Knowledge and goals for investments
  • Risk tolerance
General information to assess your situation and provide adequate and suitable services
  • Your reason for doing business with us
  • Language and communication preferences
  • Information about other individuals besides yourself (beneficiaries, your spouse or common-law partner or dependents insured under an insurance product or registered plan, an authorized user of your account, and contact information of someone you believe may be interested in a product or service from WhiteHaven*)
  • Your health and family’s health history
  • Your activities, your behaviour, your choices
Other information for training, quality control, identification, and security purposes, or to record your consent to a transaction 
  • History, recording and transcription of telephone calls, video conferences and chat sessions
  • History of meetings
  • Images captured by our security systems cameras in and around our locations
Information about digital interactions (websites, apps, chat services, text messaging, social media sites) 
  • Device information (e.g., IP address, VPN, proxies, device type and operating system).
  • Information about your approximate location that is generated using your IP address when you visit our websites
  • Browsing preferences and history, such as the webpages you visit and use frequently. For more details, please refer to our Cookies policy.
IMPORTANT! We limit the collection of your information to what is necessary to help us serve you properly.

 
1.2. How we collect your information
  • Other individuals related to your products and services
  • Other financial institutions or lenders, insurers (when we need to verify the accuracy of information provided)
  • Brokers, dealers or other stakeholders in securities or other fields
  • Credit reporting agencies
  • Publicly available sources or records
  • Regulatory bodies and self-regulatory organizations
  • WhiteHaven affiliates
  • Content generated through the use of our websites, mobile apps and social media platforms. For more details, please see our Cookies policy.
2. The use and sharing of your information
2.1 How we use and share your information

We use and share your information to:
  • Verify your identity, update your information and verify the accuracy of the information you provide
  • Assess your financial situation and creditworthiness (made on a regular basis if you have a credit product)
  • Assess your eligibility for products and services or ensure that the advice, products and services we offer or you obtain are suitable for you
  • Establish your investor profile, your financial needs and objectives as well as your investment strategies
  • Establish, manage, administer and provide the products and services requested
  • Combine the financial information that WhiteHaven affiliates hold about you to generate a 360-degree view of the products you currently own in order to provide you with better service (see your right to opt out in section 5.2)
  • Conduct research and data analytics to generate statistics, improve our products and services, and develop new ones, by analyzing the information collected by our websites and mobile apps (see your right to refuse in section 5.2)
  • Personalize your customer experience, including through analytics on your profile, transactions and other information (including information collected by our websites and mobile apps) in order to:
  • get to know you better and understand your needs
  • identify and personalize products, services and promotions that may be of interest to you and appropriate to your situation
  • provide you with better advice based on the analysis of your needs and preferences
  • Promote products and services that may be of interest to you offered by WhiteHaven affiliates or some of its partners, including personalized advertising on social media platforms (see your right to refuse in section 5.2)
  • Inform you about new features available on our mobile apps
  • Carry on our business and operations
  • Prevent, detect and control fraud, as well as any unauthorized or illegal activities (money laundering, cyber threats, etc.)
  • Enable due diligence of our operations in preparation for a business transaction
  • Manage risk, including credit and business risks, and comply with applicable laws and regulations
  • Communicate with you using the contact information you provided (by mail, email, text messages, phone calls, social media)
  • Use and disclose specific information where we are authorized to do so by law (see section 3).
2.2. To whom we may disclose your information

There are times when it is necessary to disclose your information to other parties for legitimate purposes. For example, it may be required by law, necessary to protect your interests in the event of fraud or to allow you to participate in a program with a partner or to provide services on our behalf. At all times, we are committed to limit the information to what is necessary and to obtain your consent, where required.


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

  • for identifying information, for compliance purposes and to facilitate the ongoing management of your accounts
  • for your financial information, in order to serve you better (see your right to refuse in section 5.2)
We may share your information between Whitehaven affiliates:
  • A party acting for you or at your request, such as a securities broker or transfer agent
  • Another financial institution, lender, credit insurer or credit reporting agency
  • An insurer or agent acting for us
  • A merchant, a partner through whom we offer optional products and services, a payment system, a payment card network, a compensation or settlement system, etc.
  • A person who holds an account jointly with you or who is otherwise involved in your business relationship with WhiteHaven
  • Third parties, if we need to disclose your information in the course of legal proceedings
  • A regulatory or government authority or self-regulatory organization
  • A person authorized by law to obtain it
  • Third parties, if we need to disclose your information in the course of legal proceedings
  • Social media and digital platforms with whom we may share an encoded representation of your details (e.g. your email address) to enable us to deliver targeted advertising on their platforms (see your right to refuse in section 5.2)
  • Service providers we use to perform some functions. They are part of the following categories:
  • Technology services (applications, data centre, data storage and backup, hosting services, maintenance, and support services)
  • Professional services
  • Financial and banking services
  • Insurance services
  • Communications services
  • Mail services
  • Analytical and marketing services
All the suppliers who have access to your information share our commitment to protect your information. They have adopted their own Privacy policy.

 

3. Your consent
We only use your information with your consent or as authorized by law. We obtain your consent to collect, use and disclose your information when you open an account with WhiteHaven, and if we need to use your information for another purpose than the ones for which you have already provided your consent. We do not obtain your consent for every interaction with you.

 

In addition, we do not obtain your consent in some situations provided by law, notably in order to:
  • comply with a court order or other enforceable request
  • to collect a debt
  • investigate a breach of contract or law
  • prevent, stop or detect fraud.
4. Storage and retention of your information
4.1. Time-limited retention

We retain your information, in physical or digital format, for as long as necessary to fulfill the purposes for which the information was collected or as long as required or permitted by law. The purpose, nature and sensitivity of the information have been considered in determining retention periods.

 

WhiteHaven is subject to numerous legal obligations regarding the retention of information (for example, under banking, tax and anti-money laundering laws). In general, to meet these obligations, your client file information will be retained for the duration of your relationship with us and for a period of 7 years following the end of your relationship with us.

 

Certain exceptions may apply requiring longer retention periods, for example in the case of disputes or claims. When your information is no longer required, we will make reasonable efforts to destroy it securely.
4.2. Places where we keep your information

WhiteHaven, service providers and other third parties to whom your information is disclosed under this Policy may operate outside Quebec and Canada. Your information may therefore be used and stored securely in other provinces and countries. In some cases, your information may be subject to the laws and access rights of authorities in foreign countries.


4.3. Information Security Measures

We make significant efforts to protect your information from loss, theft, and unauthorized access, use or disclosure and from any other breach of security. We have security measures in place to keep pace with changing information security threats. The measures are among others:
  • Protecting the infrastructure through secure access to our premises and secure locations for our equipment, etc.
  • Limiting who has access to your information. This means that only employees who need to know your information in order to carry out their duties have access to it.
  • Manage passwords and set up firewalls.
You have a role to play in protecting your information. We encourage you to never disclose your passwords, codes and personal identification numbers (PIN). Our employees do not have this information and will not ask you for it.
5. The rights regarding the information
5.1. Right to accept or refuse to provide your information

Your information belongs to you. Subject to legal, business or contractual requirements, you have the right to refuse or withdraw your consent for the collection, use or disclosure of information. We will process your request in a timely manner.

 

However, some types of information are essential for us to provide you with certain products and services. If you refuse to provide it, it may be difficult, if not impossible, to establish or maintain a business relationship with you or even to offer you some of our products. For example, if you do not want to provide your Social Insurance Number (SIN), we will not be able to offer you products for which it is required, such as a registered product like an RRSP.

 

5.2. Right to refuse the use of your information for specific purposes

You can refuse to let us use your information or withdraw your consent for the following purposes:

 

a. Send you promotional offers or information

WhiteHaven may, from time to time, send you promotions that may be of interest to you. You may withdraw your consent to receive these at any time by contacting us or by unsubscribing if the promotions are sent to you by email. There may be a delay before you stop receiving our promotional offers, including those from a promotional campaign already in progress.

 

We may also use an encoded representation of your email address or other contact information to create personalized audiences on social media and digital platforms. This allows us to display ads tailored to your needs and interests on these platforms. You can refuse the use of your information for targeted advertising by changing your preferences in your social media account settings or by contacting us.

 

Please note that if you withdraw your consent to this use, you may continue to see personalized offers on our websites or on social media platforms if you have consented to the use of cookies via our online banner (5.2c)). Also, you may still see some of our advertisements on social media platforms, but these advertisements will not have been targeted as a result of the use of your contact information.

 

b. Share your financial information between WhiteHaven affiliates

We may share your financial information within WhiteHaven affiliates to facilitate your interaction and relationship with us. For instance, this allows us to:
  • better serve you and to have a complete view of all the products you own within WhiteHaven affiliates (e.g., when you meet with us and request a new product or service)
  • analyze your financial situation to verify your eligibility for offers, promotions and certain products and services that are better suited to your needs
You may at any time withdraw your consent to share your financial information between WhiteHaven affiliates. Contact us and we will process your request as quickly as possible.

 

c. Collect and use your digital information on our online services

With your consent, we may collect your digital information (e.g., your device and browsing habits) using optional cookies or other similar technologies when you visit our online services. This information allows us to measure and analyze traffic to improve your browsing experience. It also enables us to provide you with offers and services that correspond to your needs. For further information, see our Cookies policy.

 

IMPORTANT! You will continue to receive even if you withdraw your consent:
  • Prescribed notices or account-related documents that we are required by law to provide
  • Information about your current products and services
You may also continue to receive information about our products and services verbally or in person from our representatives. Indeed, some of our representatives have a duty to advise you and will continue to provide you with this information when necessary.

 

5.3. Right to access your information

You may request access to the information we hold about you, except where such access is restricted by law. At any time, you may ask your representative for your information. However, any official request to access your information (e.g., to obtain your entire client file) must be placed at privacy@whitehaven.ca. We will process your request within 30 days or within a longer period if required by law. You will be notified if the timeframe is longer than 30 days.

 

5.4. Right to have your information corrected

You can and should correct inaccurate information we hold about you. To provide you with a quality service, it is essential that your information is accurate and complete. To that end, we rely on you to help us maintain the quality of the information we hold by informing us of any changes. To make a request, please refer to the procedure identified in section 5.3 above.

 

6. Contact us with any request, question, comment or complaint
To ask a question, send a comment or place a request regarding your rights :
  • Send an email to privacy@whitehaven.ca
  • Reach out to our Chief Privacy Officer, whose contact details appear at the beginning of this document.
To make a complaint, you must follow the procedures outlined in our Complaint Handling Procedure on our website.

 

NOTES:

By WhiteHaven, we refer to all affiliated entities within the WhiteHaven group, and to each of which this policy applies. The WhiteHaven group includes, but is not limited to:
  • WhiteHaven Securities Inc.
  • WhiteHaven Asset Management Inc.
We also refer to them collectively as WhiteHaven affiliates.