Virtual Brokers Electronic Communications Agreement

I agree to authorize Virtual Brokers a division of CI Investment Services. to contact me about information relating to Virtual Brokers, including special offers, products and services. I understand that I can withdraw my consent at any time by clicking an unsubscribe link provided in each email I receive or by sending an unsubscribe request HERE.

YOUR PRIVACY

We are dedicated to respecting and protecting the privacy and confidentiality of the information you have entrusted to us. This Privacy Notice outlines our privacy principles and practices.

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WHAT IS PERSONAL INFORMATION?

Personal information refers to information that identifies you. The word “information” means personal, financial and other details about you that you, or someone you authorize, provide to us or we obtain from others within or outside the Company.

WHAT DOES IT APPLY TO?

This Privacy Notice applies to the operations of Virtual Brokers in Canada. It applies regardless of how you choose to do business with us – over the phone, in person, through the internet, through your mobile device or through email.

WHO DOES IT APPLY TO?

The Notice applies to all individuals whose personal information we collect, including clients who are individuals, individuals carrying on business alone or in partnership with other individuals, signing officers of our business clients, and beneficiaries of clients to the extent that we collect, use or disclose their personal information.

CHANGES TO THE NOTICE

We may amend this Notice from time to time and will post the revised Privacy Notice on our website https://virtualbrokers.com/en/privacy.

OUR PRIVACY PRINCIPLES

The Privacy Notice outlines our privacy principles and informs you of the practices we have in place to manage personal information. We aim to respect and protect your privacy by following the key privacy principles below.

We have designated a privacy officer who is accountable for personal information under our control and responsible for compliance with this Privacy Notice. Please see Contact Us for information on how to reach the privacy officer. We have strict policies and procedures governing how we deal with your personal information. Every employee is responsible for respecting and protecting the personal information to which the employee has access.

We are committed to maintaining the accuracy of your personal information and take reasonable efforts to keep your information complete and up-to-date. We maintain your personal information in as accurate, complete, and up-to-date form as is needed for its use.

If you discover inaccuracies in our records, or your personal information changes, please notify your financial advisor or contact our Client Services Department directly so that we can make the necessary changes. Failure to notify us of changes to your personal information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your personal information that we may have released to them.

ONLINE AND MOBILE PRIVACY POLICY

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This Online and Mobile Privacy Policy supplements the Privacy Notice and specifically addresses the way in which we collect, use, disclose, and manage personal information in connection with our online, mobile and other digital channels and services. It should be read in conjunction with the Legal Notice and Terms of Use.

YOUR CONSENT

Each time you use our online, mobile, and electronic services, you are indicating your acknowledgement and consent to the collection, use and disclosure of your personal information as identified in this policy, which we may revise periodically without notice. We will let you know of any changes by posting the revised policy with a new effective date. If you do not accept the terms outlined in this policy, please do not use our online, mobile and electronic services.

WHAT PERSONAL INFORMATION DO WE COLLECT

We may collect personal information when you use our websites, online, mobile, and other electronic services (collectively, digital channels), including:

  • Personal information you provide like account and contact information, including your name, email address, user ID, password, and service preferences. Refer to your specific app for additional, applicable information.
  • Financial information – that you provide to us at the time of account creation of an account through our online or mobile account creation process
  • Transactional data about your use of our products and services
  • Mobile phone number
  • Device-related information like:
    • Internet Protocol (IP) address - An IP address is a unique set of numbers assigned by Internet Service Providers (ISP) to all devices used to access the internet. While CI is not able to identify an individual using the IP address alone, in certain circumstances, it could be used to identify an individual using the site.
    • Mobile country code which is a three-digit number that indicates the country in which your mobile device is registered (for example, 302 is the mobile country code for Canada)
    • Geolocation (if enabled on your device) provides the approximate physical location of your device
    • Device ID which is a unique number that identifies your device
    • Make and model of your device
    • Operating system of your device
    • Information about screen size of your device
    • Date and time of your use of our app
    • Browser data
    • Software applications data
    • Mobile device identification number (IMEI)
    • Mobile Marketing ID (if enabled) such as AAID and IDFA
  • Statistical information about how users interact with our digital channels, such as average time spent on a specific mobile or web page.
  • Website use information, such as browsing behaviour on our websites and links, location you click, form data and downloads, as well as other data gathered from the use of web tools (for example, Cookies, Web Beacons, Tagging)
  • Other information, such as any feedback you may provide us

FOR WHAT PURPOSES DO WE USE AND DISCLOSE YOUR PERSONAL INFORMATION

We may use or disclose this information collected online to:

  • Verify your identity and authenticate you during online sessions
  • Provide and manage the online products and services
  • Provide you with services and offers compatible with your device and relevant to your region
  • Determine eligibility of your device
  • Protect against fraud, security threats, and otherwise manage risks
  • Communicate with you regarding products and services that may be of interest, including displaying targeted and relevant advertising, and offering you special promotions
  • Evaluate and improve our websites, online apps, mobile apps, and other electronic offerings
  • Tailor our services and otherwise enhance the online customer experience to better meet your needs through digital channels
  • Perform analytics and measure the effectiveness of our digital channels and services, including obtaining insight into how to improve the design, content and navigation of our digital channels
  • Satisfy legal or regulatory requirements

USE OF WEB TOOLS

We and our service providers may use various tracking tools, such as [Cookies, Pixel Tags and Web Beacons]. Through the use of cookies and other technologies, we can enhance your experience with improved design, personalized content that may be relevant to you, and effective navigation.

  • Cookies: A Cookie is a string of data containing a unique identification number that our website sends to your computer’s web browser. We use cookies and online tools, such as Google Analytics, to collect non-personal information to understand how people are using the Services and how we can make them better. Most browsers and mobile devices offer their own settings to manage cookies. You can refuse or delete cookies. When you first visit our website, you will be presented with a banner which allows you to review the various category of cookies that are on our website and select which category of cookies you would like to accept. Additionally, you can refer to your browser’s online help for further instruction and information on setting Cookie preferences.

    If you do not accept any category of Cookies, you may continue to browse our websites; however, please be aware that certain features of our website may not function properly without Cookies. You should note that if you would like certain services, you will be required to accept the Cookies to maintain session integrity and enhanced security. Additional resources that may assist you in managing Cookies used for advertising include the Digital Advertising Alliance (DAA): https://youradchoices.ca/.

    If you refuse a cookie when using the Services, or if you delete cookies, you may experience some inconvenience in your use of the Services. For example, you may not be able to sign in and access your account, or CIIS may not be able to recognize

  • Tagging: Tagging software is customized code on our websites, designed to monitor user activity on our websites, to help us in presenting users with content relevant to their use of our website.
  • Web Beacons: Web beacons are small and transparent images embedded in web pages and e-mail communications that, when combined with Cookies, help provide us with information about the use and effectiveness of a website or e-mail communication. As an example, we may include web beacons within e-mail communications to receive confirmation of receipt of an e-mail communication or clicks on links within our websites.

YOUR CHOICES

  • EMAIL COMMUNICATIONS: Virtual Brokers a division of CI Investment Services Inc. uses electronic messages and e-mail to contact clients about information relating to Virtual Brokers, including special offers, products and services. You may withdraw you consent at any time by clicking an unsubscribe link provided in each e-mail I receive or by sending an unsubscribe request HERE [link to unsubscribe mechanism].
  • Voluntary Participation: You may choose to enter your information to participate in online surveys, feedback, contests, or other activities we sponsor. We use this information for a number of purposes, such as assessing the performance of the website, or improving products and services, or identifying products and services that might interest you. This information will be used for the purposes outlined in the Privacy Notice. If you do not want your information used for the disclosed purposes, do not participate in these voluntary activities.
  • Educational webinars: You may choose to enter your information to participate in online meetings, educational events that we sponsor. We use this information for a number of purposes, such as assessing the performance of the website, or improving products and services, or issuing continuing education credits. This information will be used for the purposes outlined in the Privacy Notice. The information you enter may be transmitted through or to our 3rd party providers of webinars. If you do not want your information used for the disclosed purposes, do not participate in these voluntary activities.
  • Use of Electronic Signature - In the event you choose to utilize electronic signature features included in any of our online Services, you agree to the collection and retention of your IP address for the purposes of identifying you, maintaining evidence of transaction authorization, fraud protection and security.

SAFEGUARDS:

Our Security Measures

We take our responsibility to safeguard customer information very seriously. To protect certain communications between your computer and our servers, we use a technology solution called “Secure Sockets Layer” (SSL). SSL ensures that the information transmitted is encrypted. In addition, we use the concept of “defense in depth”, in our cybersecurity program that has many layers, from employee awareness to having firewalls at the very edge of our network.

Your Security Measures

You are responsible for ensuring the security of your unique web login ID and password. You must avoid selecting an obvious password, such as a street address, date of birth, or telephone number and to change your password on a regular basis, in order to reduce the potential for unauthorized use. Any web login ID, password, or any other piece of information chosen by you or provided to you as part of CIIS’s security procedures, must be treated as confidential and personal to you, and you must not disclose it to any other person or entity.

Do not respond to text messages, pop-ups, emails, or other internet requests that ask you to reveal personal information about yourself or your account when using the Services. CIIS will never send you unsolicited messages or emails asking for your password, credit card, account numbers, etc. CIIS will never ask you to validate or restore your account or access to the Services through unsolicited messages or emails.

THIRD PARTY LINKS:

For your convenience, the Services may provide links or pointers to third party sites. You are subject to any terms and conditions of such third-party sites. Non-CIIS websites are not subject to CIIS’s privacy policy or security standards.