Client Confidentiality Policy
Palos undertakes to protect the confidentiality and ensure the security of the personal information of its clients. This Client Confidentiality Policy explains the measures the firm has taken to abide by this policy.
COLLECTION AND USE
Your Personal Information is private and confidential. From time to time Palos will collect, use, and (with strict limitations) share your personal information. Palos has adopted a privacy policy and has taken steps to protect private information and to ensure compliance with privacy legislation. Palos observes the following principles at all times:
- Accountability. Matters of privacy are considered at the highest levels of Palos’ organization. All of our staff are informed of the importance of protecting the privacy of our clients.
- Limited Collection. Palos only collects the information it needs in order to deliver services to you.
- Limited Purposes. Palos collects information only in order to deliver services to you. This may include telling you about a service you are not already using, but that may be of interest to you.
- Consent. Palos seeks your consent to collect and use your personal information. Palos typically obtains this consent in the agreements you sign when you become a Palos client. You are free to withdraw your consent at any time. However, withdrawing your consent may limit the services that Palos is able to offer you.
- Limited Use and Retention. Palos uses your personal information only in ways that you allow or if required by law. Palos keeps your personal information only as long as necessary or as required by law.
- Accuracy. Palos seeks to ensure that the personal information it collects is as accurate as possible.
- Controls. Palos has imposed controls to ensure that your personal information is secure.
What types of information does Palos collect? Palos will collect information to establish your identity (for example, name, address, phone number, date of birth, etc.) and your personal background, including your employment history and the source of the money you are investing. Palos will also maintain a record of any information you provide on your client forms, as well as any investments we provide advice on.
Why does Palos collect this information? Palos collects information for three main reasons: because we are required by law, to ensure that we are providing you with appropriate advice, and to learn more about you so that we can provide you additional services.
What does Palos do with the information it collects? Palos uses the information to verify your identity and investigate your personal background; to provide investment services such as opening, operating and managing your accounts; to better understand your financial situation; to determine your eligibility for products and services we offer; to help us better understand your current and future needs; to help us better manage our business and our relationship with you; and as required or permitted by law.
We never sell or give client lists or client information to other companies or third parties for their own use.
Who else may access that information? Palos strictly controls access to your information and shares it only as necessary. Palos may make your information available to our employees, agents and service providers, but in such a case Palos will ensure that they are required to maintain the confidentiality of that information. Palos may also share this information between its different entities (Palos Management Inc. and Palos Wealth Management Inc. may share information, for example).
Palos has the right to communicate information regarding you to government bodies and entities or to regulatory authorities in order to comply with laws, regulations, subpoenas, formal or official requests or any other similar procedure, within the limits provided by law.
Palos may also be required to share information with other investment dealers, service providers, and securities regulators. For example, client information may be shared with our outside service providers that have access for the purposes of providing tax statements, client statements and fulfilling client transactions; businesses that provide other goods and services to Palos, such as data processors and record keepers; intermediaries, such as trustees and custodians; and regulatory organizations, such as Canadian provincial and territorial securities regulators.
Palos may also use this information to verify your creditworthiness; to manage our risks; to comply with valid requests for information about you from regulators, government agencies, public bodies or other entities who have a right to issue such requests; and for tax-related purposes for reporting to the appropriate government agencies if you hold a product that generates income and may share it with.
YOUR RIGHT AND ROLE
Your right to access your personal information. The file containing your personal information will be kept at Palos’ offices, and you may access it during normal business hours and upon reasonable notice to Palos, unless that access is restricted by law. If you have any questions or concerns, 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.
If you require us to provide information concerning you to a third party, such as an accountant, tax specialist, notary or another person, you must inform us in writing, stating the person’s identity and contact information, and describing the information to be provided.
Your role. You have an important role when it comes to your investments. For us to give you the best possible advice, we need to understand you, your goals, circumstances, and any other relevant factor that could potentially affect our investment decisions. In that respect, we ask you to always keep us up to date. Please provide us full and accurate information about yourself and your circumstances. Promptly inform us of any changes to your information that could result in a change to the types of investments appropriate for you, such as a change in your income, investment objectives, risk tolerance, time horizon or net worth.
WEBSITE TERMS AND CONDITIONS OF USE
It is important that you read and understand this Important Legal Information page. This website is owned and managed by Palos Capital Corp. and/or Palos Management Inc. (collectively, “Palos”). By visiting this website, you accept and agree to comply with the terms and conditions of use, which may be modified from time to time without notice. Any changes to the terms and conditions of use of this website will be made directly to this page. Please look at all changes and updates. Each time you visit the website, we presume that you have read and accepted the terms and conditions of use. By visiting or using the services offered through this website, you signify that you accept the terms and conditions of use, including any changes to them. If you do not accept the terms and conditions, you must not use this website. The terms and conditions and your use of this website are governed by the laws of the Province of Quebec and all other relevant laws of Canada.
LIMITATION OF LIABILITY
The information or data contained on this website are provided exclusively for general information purposes. This information or data must not be construed as advice that applies to your financial situation or as specific advice of a financial, legal, accounting, tax or investment nature. You should always consult your personal financial, legal, accounting, and/or tax advisor prior to making any decisions regarding your personal financial position.
The information contained on this website is deemed to be accurate and reliable at the time of publication on the site; however, we cannot guarantee that it will remain accurate, reliable, complete or up-to-date. We assume no responsibility for any losses incurred due to the use of this website or to the unavailability of this website. Unless specifically noted to the contrary, the information on this website is not verified and is provided “as is.” We make no claims that this website will not experience interruptions or be free of errors, that such flaws will be corrected, or that the site or the server that hosts it is free of viruses or other harmful elements.
AVAILABILITY OF PRODUCTS
The products and services referred to on this website are subject to the terms and conditions of applicable laws. Palos funds are provided only in certain provinces and territories of Canada or other jurisdictions where they may be offered lawfully. Palos funds are not all provided in all jurisdictions outside Canada. The information contained on this website is not an offer or solicitation to buy or sell any funds, investments, or any other product, service or information. Potential investors who do not live in Canada should consult their financial and/or legal advisors to find out if these securities are offered lawfully within their jurisdictions.
These securities may not be suitable for you. You should always consult your personal financial, legal, accounting, and/or tax advisor prior to making any investment decisions.
If you choose to use this website outside Canada, you are responsible for complying with all relevant local, national and international laws. You may not use, export or re-export any information contained on this website, or copy any parts in violation of any relevant laws and regulations, including the laws and regulations relating to exporting from Canada.
COPYRIGHT
All information on this website is protected by applicable copyright laws. It is prohibited to copy, distribute, modify, post or use any text, image, video clip, program code or user interface design or logo. Any unauthorized use or reproduction of these brands and names is strictly prohibited.
HYPERTEXT LINKS
Reference on this website to the products or services of third parties does not signify that Palos endorses or approves such products or services and is provided only for convenience. Palos neither endorses nor approves links to other websites, third parties, or their products or services, and is not responsible for any incompatibility, inconvenience, contamination by computer viruses or worms, Trojan horses or any other destructive agent originating from these sites. Linking to other sites is at your own risk and Palos will not be held liable for any damage caused by such links.
GENERAL WAIVER OF RESPONSIBILITY
Past results do not guarantee results in the future. The returns shown are overall annual composite historic yields that include changes in the value of the securities and reinvestment of dividends and distributions. Returns are based on net asset value per share calculations performed by Palos, based on information provided to Palos by commercially available financial information providers.
The information contained in this communication is subject to change without notice and Palos cannot be held responsible for any inaccuracies in the information provided. It is prohibited to download, retransmit, record on any support whatsoever, copy, redistribute, reproduce or republish it for any purpose. The information contained on this website does not constitute specific advice of a financial, legal, accounting, tax or investment nature. Please consult your personal advisor before making any investment decisions.
INTERNET E-MAIL
The confidentiality and security of e-mail transmissions over the Internet is not guaranteed. E-mail communications are not confidential and may be intercepted, lost or even modified. Palos is not responsible for harm or damages that you or any other person may suffer by transmitting e-mail containing personal or confidential information via the Internet to Palos, or from e-mail that Palos sends to you at your request.
USE OF THE WEBSITE
Palos is not responsible for any damage (direct, indirect, special, economic, consecutive, constructive, exemplary or punitive) incurred following use or unavailability of this website, its content, or any action or decision taken by you or another person based on the website, its content or any other unauthorized use or reproduction of the website or its content.
Like other types of communication, unprotected e-mails are not confidential and can be lost, altered, modified and even intercepted. Palos will accept no liability toward you or anyone else for damages resulting from transmission of electronic message to or from Palos. As a reminder, other means of communication for sending information to Palos can better protect personal information when deemed necessary.
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.
