Your personal information is important. At Palos, we want you to understand how we collect, use, and share personal information of our clients. We follow a strict privacy policy and take steps to protect your information and comply with privacy laws. 

Our Privacy Principles

We follow these key principles to safeguard your personal information:

1. Accountability – Privacy is a priority at every level of our organization. Our staff are trained on the importance of protecting your information.
2. Limited Collection – We only collect the personal information necessary to provide you with our services.
3. Limited Purpose – We use your information only to deliver our services or tell you about services that may be of interest to you.
4. Consent – We ask for your consent to collect and use your personal information, usually when you sign our account opening documents. You can withdraw your consent at any time, but this may limit our ability to serve you.
5. Limited Use and Retention – We use your information only as permitted by you or required by law. We keep it only as long as needed.
6. Accuracy – We take reasonable steps to keep your information accurate and up to date.
7. Controls – We have physical, organizational, and technological safeguards in place to protect your personal information.

What Personal Information We Collect

The types of personal information that we collect, use, and share depend on the product or service you have with us. This information may include:

• your name, address, telephone numbers (including mobile), email address, date of birth, and Social Insurance Number (SIN) or Social Security Number (SSN);
• your personal circumstances and profession;
• your assets, income, and source of funds; and
• your investment experience, investment goals and risk tolerance.

It may also include technical information such as your IP address, device type, and browser when you access our website or use our forms, to the extent that this information identifies you.

In some circumstances, we may need information about related parties to manage our relationship with you, such as your spouse, partner, trusted contact person, or beneficiaries.

We keep a record of the information you provide to us through client forms or conversations, and of any advice or services we provide.

Why We Collect This Information

We collect and use your personal information to confirm and verify your identity, provide you with personalized investment services, help us manage our business and our relationship with you, conduct background and credit checks as required, and meet legal, regulatory, and tax reporting requirements.

We also ask your consent to receive promotional materials via electronic means.

How Do We Use or Share Your Personal Information

To administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to your personal information within Palos or to certain non-affiliated companies. We may share your personal information:

• To process your transactions, maintain your account(s), respond to court orders and legal investigations, report to credit bureaus, or to satisfy legal and regulatory requirements from securities regulatory authorities, government entities and our outside auditors.
• With third party administrators and vendors for servicing your account (such as transaction history, tax information and performance reporting).
• With affiliated and non-affiliated entities that perform services for us or function on our behalf (such as investment dealers, trustees, custodians, data processors and record keepers).
• With regulatory agencies when they examine or query our firm; or
• As otherwise permitted or required by law.

Palos may also use your information to offer products and services that may be of interest to you. Please note, however, that we do not sell your personal information.

Automated Processing

We may use limited forms of automated processing, such as for placing trades according to predefined rules or instructions. These processes do not produce legal or similarly significant effects without human oversight. If you have any questions, please contact your Palos advisor.

Safeguarding Your Information

We strictly control access to your personal information. It is shared only with employees, agents, and service providers who need it to perform their duties and who are obligated to keep it confidential. We use administrative, technical, and physical safeguards to protect your personal information from unauthorized access, loss, misuse, or disclosure.

Retention and Destruction of Personal Information

We retain your personal information only as long as necessary for the purposes it was collected, including to meet legal, regulatory and tax reporting requirements. Typically, records are kept for at least seven (7) years after creation. When no longer needed, information is securely destroyed or anonymized in accordance with our retention policy.

Consent to Collection and Use

We collect, use, and disclose your personal information with your knowledge and consent, except where otherwise permitted or required by law. Consent may be express (e.g., written or verbal agreement) or implied (e.g., by using our services or submitting information through our forms).

For example, we collect your information when you

• Open an account with us;
• Seek advice about your investments;
• Provide personal information to help us better understand your needs.

We may also obtain your personal information from others, such as credit-related information about you from credit reporting agencies to verify your identity.

Withdrawing Consent to Collection and Use

You may withdraw your consent for our collection, use or disclosure of your personal information. You may also opt out of receiving certain communications, such as newsletters or promotional materials. To do so, please inform your Palos advisor or send an email at: [email protected], We will continue to send you information related to the services or accounts you maintain with us, such as regulatory notices or transaction updates.

Please note: Some personal information is necessary for us to deliver services. Without it, we may not be able to meet your needs effectively. In some cases, we may need to close your account or stop certain services if you restrict our ability to share information with key third parties or fulfill our legal and regulatory requirements. Your Palos adviser can explain the impact of these decisions based on your specific situation.

Your Role

You play a key role in helping us provide sound advice. To serve you properly, we need a clear understanding of your financial goals, outlook, and personal situation. Please ensure the information you provide is complete and accurate. Notify us promptly if there are changes to your circumstances—such as income, investment objectives, risk tolerance, time horizon, or net worth—so we can ensure your investment strategy remains suitable.

Your Rights

Subject to applicable laws, you have the right to:

• Access your personal information held by us;
• Correct inaccurate or incomplete information;
• Request to receive some of your personal information in a commonly used format;
• Request the deletion or anonymization of your data when no longer required;
• Object to certain types of information processing, including for marketing;
• Be informed about and object to the use of automated decision-making systems;
• File a complaint with our Chief Compliance Officer or the relevant privacy authority.

Transfers Outside of Québec or Canada

Before communicating personal information outside Québec or across borders, we conduct a Privacy Impact Assessment to ensure adequate protection and compliance with applicable laws.

Privacy Contact

If you have any questions regarding Palos’ privacy policy, or wish to exercise your rights,, please  call us at 514-397-0188 or toll-free at 855-725-6788 or write to us, to the attention of the Chief Compliance Officer, at our Montreal office: Palos Wealth Management Inc, 1 Place Ville Marie, Suite 1670, Montréal, Québec, Canada H3B 2B6, or at [email protected].

Palos reserves the right to modify or supplement its privacy policy at any time. If we make a change to the privacy policy, we will post the amended policy on our website at www.palos.ca.