Privacy Policy
We have established protocols to prevent the loss of, unauthorized access to, or disclosure of personal and/or confidential information that we collect about our clients (“client information”).
“Personal information” is defined in Canadian law as information about an identifiable individual and includes, but is not limited to, race, national or ethnic origin, religion, age, marital status, medical, education or employment history, financial information, email address, location, IP address, DNA, social insurance number and driver’s license number.
Purpose of Collecting Client Information
Rally collects client information to:
- Open an account
- Identify and help protect clients against possible fraud or other malfeasance by a third party
- Identify any actual or potential conflicts of interest between a client and Rally
- Satisfy our “know your client information” requirements under securities law
- Meet our obligations under Canada’s anti-money laundering, anti-terrorist financing and income tax laws
- Meet requirements set out in any contractual agreements with a client
- Subscribe for investment fund units to be held in a client account or to assist clients with a subscription for such units
- Provide a client with account statements and related reports
- Provide information to a client about securities, financial markets, events, news, and other matters related to your investment interests and objectives; and
- Support sales and marketing
Methods of Collecting Client Information
Rally, or an entity acting on behalf of Rally, collects client information from you through client onboarding forms and documents, in person, online or by telephone or email. Rally may also collect such information from publicly available sources and when you visit our website.
Cookies and Log Files
We could collect information through log files and cookies. These allow us to process statistics and information on traffic on the website, to ease navigation and improve your experience.
We use third-party web analytics services on this website; namely, Google Analytics. The analytics provider uses technologies such as cookies, web server logs and web beacons to help us analyze how visitors use this website. The information collected through these means (including IP addresses) is disclosed to the analytics provider, who uses data to evaluate use of this website. To learn more about Google Analytics and how to opt out, please visit: https://tools.google.com/dlpage/gaoptout
a) Cookies used by the website
The cookie files used by the website are the following:
- IP address
- Pages visited and queries
- Day and time of connection
The use of such files allows us to achieve the following purposes:
- Improvement of the website
- Statistical surveys
- Perform analytics
b) Objection to the use of cookies and log files by the website
You have the right to object to the recording of these cookies and log files by configuring your web browser. Once you have deactivated cookies and log files, you may continue your use of the website. However, any malfunction resulting from this deactivation may not be considered of our making.
Disclosure of Client Information
We may disclose your client information to comply with securities, income tax and other laws; a subpoena or warrant or an order made by a court, person, or body with jurisdiction to compel the production of information; court rules regarding the production of records and information; or as otherwise required or authorized by law.
We may also disclose it to third parties that provide services to us (“service providers”), to your custodian(s), and to the managers of investment funds whose units we buy on your behalf.
Note that investment funds are required to file reports with the relevant securities regulatory authority setting out a fund unitholder’s name and address and certain details about the unitholders’ investment in a fund.We will disclose only such client information as required under the circumstances.
The personal information collected by the website is not transmitted to any third party and is processed only by us.
Storage and Protection of Client Information
Client information will be stored in a protected digital environment controlled by us or one of our service providers, or in stored in paper format in secure filing cabinets in our office.
We use various means to protect client information including:
- Rules about who can access the information
- Digital user account management protocols limiting access to certain files
- Locked cabinets and offices
- Confidentiality agreements if and where applicable
- Usernames and passwords stored using a secure password manager
- Multi-factor authentication on electronic logon credentials
- Around-the-clock network monitoring and IT service provider support
- Automatic data backup
- Digital certificates, firewalls and SSL protocols
- Employee training on privacy, cybersecurity and related issues.
We require our service providers to use client information only for the purposes specified in our agreements with them and to have appropriate measures in place to safeguard the information.
Retention of Client Information
Client information collected by us will be retained for seven years unless more stringent regulatory or contractual requirements apply. Client information collected to satisfy our AML and ATF related requirements will be retained for five years after the closing of a client account. Client information collected for any other purposes is kept only for as long as such information is required.
Our websites are hosted by: WHC, located at the following address: 7250 Rue Clark #301, Montréal, Québec H2R 2Y3 Canada. The host may be contacted at the following phone number: 1 514 504-2113. Personal information we collect and process is not transferred outside Canada.
Privacy Breaches
We will notify the affected client and the Office of the Privacy Commissioner of any privacy breach where it is reasonable to believe that the breach creates a real risk of significant harm to the client.
Significant harm includes humiliation, damage to reputation or relationships, and identify theft. Determination of whether a real risk exists will be based on, among other things, an assessment of the sensitivity of the information and the probability of its misuse.
In an event that one of our employees becomes aware of a potential or actual privacy breach, the employee must immediately advise our Chief Compliance Officer of the situation. The Chief Compliance Officer will seek to determine the root cause of the breach, its scope, any associated risk of significant harm to a client and any corrective action to be taken.
Access to and Correction of Client Information
Subject to certain limited exceptions prescribed by law, you will be given access to your client information and are entitled to challenge the accuracy and completeness of the information and have it amended as appropriate. You can help us maintain the accuracy of your client information by notifying us on a timely basis of any changes to it.
Right of Objection and of Withdrawal
You have the right to object to the processing of your personal information by the website (“right to object”). You also have the right to request that your personal information does not appear, for example, on a mailing list (“right to withdraw”). If you wish to exercise the right to object or the right to withdraw, you must submit a written request via email at compliance@rallyassets.com
Right of Access, of Rectification and of Removal
You have the right to consult, update, modify or request the removal of information about you by submitting a written request to compliance@rallyassets.com
Questions, Concerns and Complaints
If you have any questions, concerns or complaints about your privacy and the confidentiality of your personal information, or if you would like access to your personal information that we have on file, you may contact our Privacy Officer, Iryna McCoubrey at compliance@rallyassets.com or 416-861-1717. You can also contact the Office of the Privacy Commissioner of Canada with privacy-related questions at (819) 994-5444. We may periodically update our Privacy Policy and when we do so we will post the updated version on our website and, where there are material changes made to it, circulate it to our then current clients.