PRIVACY POLICY

Catallaxy (“we” “us” or “our”) is committed to ensuring the protection and confidentiality of the personal information that you provide or that we collect when you visit our website or interact with us. In this regard, this privacy policy (hereinafter the “Policy”) aims to inform you of the personal information that we collect as well as how this same information is used, communicated, and saved by us. The Policy is designed to comply with applicable laws regarding the protection of personal information.

1. Personal Information Categories

In this Policy, “personal information” means all information about an individual that identifies that individual, directly or indirectly, that may include, but is not limited to:

• your contact information, such as your name, surname, mailing address, email address and telephone number;
• your financial information, such as information relating to your income, your salary, other benefits, your tax returns, including your social insurance number;
• recruitment information, such as a resume, education and employment history information, details of professional affiliations, diploma from educational institutions and other information relevant to a potential recruitment or employment;
• billing and financial information, such as billing address, bank account information or payment data;
• service-related information, such as details of services we have provided to you;
• information provided to us by or on behalf of our clients or generated by us in the course of providing our services, which may, where required, include special categories of personal information (such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sexual orientation, etc.);
• identification and other background check data, such as a copy of a driver’s license, passport or utility bill, proof of beneficial ownership or source of funds information, required to comply with anti-money laundering laws and collected as part of our engagement acceptance and ongoing monitoring procedures;
• marketing information and communication preferences;
• data on your browser’s cookies, linked to your use of our website or portals, including your IP address, user ID, language, date and time of visit and pages viewed. For further information on this subject, please consult our Cookie Policy;
• any other personal information about you or third parties that you provide to us.

We do not knowingly collect information from children or others under the age of 14. If you are a minor under the age of 14, please do not provide us with any personal information without the express consent of a parent or guardian. If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us.

2. Collection of Personal Information

We may collect personal information directly from you when you visit our website, do business with us or interact with us. We may also collect personal information indirectly from any source, including, but not limited to, sources specified in any agreement between you or an agent acting on your behalf and us, your current or former employer(s), financial institutions, personal information agents, employment agencies, consumer reporting agencies, credit reporting agencies, government agencies, or from your authorized representatives, such as your financial advisor, any person you may have given a reference or any other source necessary to provide our services.

3. Use of Personal Information

The personal information we collect is used only for the purposes indicated at the time of collection or any other use permitted or required by applicable laws, including:

3.1 Providing Services to our Clients

For example, we may use personal information to provide our services, to conduct our business, including fulfilling our obligations under any agreement we have with you. As part of the professional services we provide to our clients, we may process personal information from individuals with whom we do not have a direct relationship (contractual or otherwise). In such cases, we ask our clients to confirm that they have the authority to provide us with personal information in the context of the provision of services and that this data has been processed in accordance with applicable law.

3.2 Any Activity that is an Integral Part of our Firm’s Operations

We may also use your personal information for the purposes of, or in connection with:

• recruitment of potential employees, partners and contractors, as well as management of the relationship with employees, partners and contractors;
• inquiries of and communications with governments, regulators, courts and law enforcement authorities;
• client account opening, client relationship management, accounting, and billing;
• compliance with our legal, regulatory or risk management obligations as well as those of our clients and service providers;
• fraud prevention;
• any other use permitted or required by applicable laws.

3.3 Maintaining a Distinctive Client Experience

In addition to the purposes connected to our firm’s operations above, we may also use your personal information to:

• communicate with you and keep you informed to send you an appointment confirmation, to respond to a question asked, a comment or a request for information, to respond to your quote request, to send you our newsletter if you have agreed to receive such communications, etc.;
• distribute marketing materials to individuals on our mailing lists (invitations, expert content, news, etc.). You can unsubscribe from our mailing lists at any time;
• conduct monitoring and benchmarking of targeted marketing activities and marketing programs;
• conduct data analysis and research including, developing and adapting our products and services, determining the suitability of our products and services;
• manage and improve our website;
• adapt the content of our website so that you have a personalized experience.

4. Communication of Personal Information

We undertake not to communicate personal information for purposes other than those for which it was collected, unless you consent, or applicable laws permit or require it. We may engage third parties, including service representatives and members of our network, to process personal information for the above purposes.

4.1 Communication to third parties

We may disclose your personal information to third parties, including:

• third party service providers who support our services or who provide services on our behalf, such as data hosting and processing, IT support, customer service, marketing and analytics, and other services. We do not authorize them to use or disclose personal information for their own commercial or other purposes;
• members of our network who provide services for us within the framework of the professional services we provide to you;
• professional advisors, such as law firms, tax advisors or auditors;
• insurers;
• regulatory bodies and other professional bodies;
• tax authorities, securities authorities, credit rating agencies;
• federal or provincial agencies and regulators in response to a search warrant, court order or other request or inquiry that we deem valid;
• any person or organization, including an investigative body, to prevent, detect or suppress financial abuse, fraud, or criminal activity, to protect our assets and interests, or to manage or resolve any actual or potential losses, or in the event of violation of the law;
• any business in the event of a corporate reorganization or other change of control of our firm;
• any other third parties where the law requires or authorizes such disclosure.

4.2 Sharing of Personal Information Between Affiliates

Unless prohibited by law, we may share your personal information with our affiliates or our various departments within the Raymond Chabot Grant Thornton Group, for the following purposes:

• manage your business relationships with us and our affiliates;
• comply with any requirements prescribed by law or regulations;
• provide you with services that you have requested from us.

4.3 Communication outside of Canada

Some of these third parties may be located in Canada or other jurisdictions or countries and, therefore, your personal information may be processed, accessed or stored outside of Canada. They may disclose information in response to valid requests from governments, regulators, courts and law enforcement authorities in such jurisdictions or countries, in accordance with applicable law in such jurisdictions or country.

5. Retention of Personal Information

We will retain your personal information for as long as it is necessary for the purposes for which it was collected, subject to legal and professional requirements relating to the retention of certain types of information.

6. Consent

We make sure you understand the purposes for which we use or disclose your personal information. Your consent may be express, implied, or provided by your authorized representative. By using our website or by transmitting your personal information to us, you consent to this Policy and to the collection, use, disclosure and storage of your personal information in accordance with this Policy. Except where the law provides otherwise, you can withdraw your consent to the communication or use of the information collected by contacting us using the contact details provided in the Contact us section. In some cases, withdrawing your consent could affect the services that may be offered to you or the functionality of our website or portals.

7. Security Measures

We follow the standards that are generally applied and recognized for this purpose, in order to ensure the protection of personal information. We maintain physical, organizational, contractual and technological security measures to protect your information against accidental or unlawful destruction, accidental loss, modification, unauthorized disclosure or access, misuse or other unlawful form of processing of personal information in our possession. We take steps to ensure that only authorized individuals who have a need to know personal information, or whose duties reasonably require knowing it, have access to it. Third parties to whom personal information is communicated must comply with the security measures we have implemented.

Despite the measures described above, no method of transmission over the Internet, nor any means of electronic storage, is completely secure. We therefore cannot guarantee the absolute security of your personal information. If you have reason to believe that your personal information has been compromised, please contact our Privacy Officer immediately using the contact details provided in the Contact us section.

8. Links to Third Party Websites

For your convenience, our websites may provide links to third party sites or portions of their sites. We have no control over the content or operation of these sites or the confidentiality or privacy practices of the operators of these sites. Therefore, any personal information you submit through these sites is governed by the privacy policies of the sites in question. It is therefore your responsibility to find out about their policies for protecting information that concerns you.

9. Rights concerning your Personal Information

In certain circumstances and in accordance with applicable laws, you have certain rights with respect to your personal information. Upon written request, you have the following rights in relation to your personal information:

• access: you may be informed of the existence, use and disclosure of your personal information and you may have access to that personal information within a reasonable time. You can also request that your computerized information be communicated in the form of a written and intelligible transcript;
• rectification: you have the right to have the personal information we hold about you amended and updated if it is incomplete, out of date or inaccurate;
• withdraw your consent: you have the right to withdraw or modify your consent to the communication or use of your personal information at any time, subject to applicable legal and contractual restrictions;
• de-indexing: you have the right to ask us to stop disseminating your personal information and to de-index any link attached to your name which gives access to this information if this dissemination contravenes the law or a court order;

You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions provided for by applicable law.

10. Contact us

For any questions, concerns about this Policy or about the protection of your personal information, to exercise your rights or to file a complaint, please contact our Privacy Officer by email at [email protected] or by mail to the following contact details:

Raymond Chabot Grant Thornton
c/o Privacy Officer
National Bank Tower
Suite 2000, 600 de la Gauchetière Street West
Montréal (Québec) H3B 4L8

Please provide sufficient detail in any correspondence you send to us to enable us to identify what information you wish to access or correct, if applicable. We recommend that you secure your emails. Please note that we may ask you to verify your identity before responding to your request.

11. Update

We reserve the right to modify this Policy at any time. Any changes to the Policy will become effective when we post the revised version on our website. By continuing to interact with us after the revised version of the Policy is published, you accept the changes made. We therefore invite you to read this Policy regularly in order to remain informed of the way in which we process your personal information. The date at the bottom of the Policy indicates when it was last revised.

Last update: September 22, 2023