Last Updated: February 26, 2024
Personal Information encompasses information about identifiable individuals. Beyond standard elements considered Personal Information (like your name, email, address, phone number, etc.), what makes you identifiable is sharing different pieces of data that, alone or in conjunction with other data, allow us to unequivocally identify you. By way of illustration, your name without further data elements like an address or postal code is unlikely to be categorized as Personal Information because other people may have the same name, as such we may not be able to identify you with certainty.
2. Processing of Personal Information
2.1. Legal Bases
We process your Personal Information based on:
- Your provision of consent (where applicable),
- Your contract with us,
- exceptions to the consent requirement as outlined in the law; or
- in line with legal or regulatory requirements or guidance.
2.2. Collection of Personal Information
We collect Personal Information necessary to provide information, products, or services of your choice. With limited exceptions, we collect your Personal Information directly from you through our website, emails, phone, fax, physical forms, internal systems, marketing campaigns or lists, etcetera. From time to time, we utilize publicly accessible information where necessary to verify information provided by you.
When you disclose to us the Personal Information of another person for use in connection with our products or services, for example, a beneficiary or a family contact, you must be authorized to entrust that Personal Information to us.
2.3. Processing Purposes
We process your Personal Information for the following purposes and, where applicable, for secondary purposes that are compatible (meaning reasonable, necessary, and proportionate) with the ones listed below:
- Overseeing compliance with legal and regulatory obligations on an ongoing basis. This includes, for example, responsibilities related to prevention of tax avoidance and fraud, Know Your Client (KYC), Anti-Money Laundering, and Anti-Terrorism Financing (AML/ATF), which trigger, among others, a suitability assessment to analyze risks involved in a potential business relationship. We must also comply with legal and regulatory disclosures involving the user or transfer of your Personal Information to the requesting authority.
- Initiating, establishing, and managing a business relationship and the termination of that relationship.
- Providing you information, products, and services of your choice, maintaining those products or services, and identifying and sharing with you information, products, or services that may interest you.
- Managing any requests derived from your business relationship with us (like purchases, redemptions, distributions, reinvestments, transfers, fees, and commissions payable). Depending on the context, this may include liaising with different financial institutions and providers, and exchanging Personal Information with them, as well as involving other entities within the Skyline Group of Companies (for example, as required for our finance department to process different transactions).
- Connecting you with plan trustees and, where needed, assisting you in setting up your account.
- Sending you or making available account statements and organizing and communicating with you about investor educational seminars.
- Connecting you with our partners (i.e., insurance providers) pursuant to referral agreements, where you express interest in knowing more about their products or services (note that this process may involve the disclosure of Personal Information).
- Additionally, we process your Personal Information for business purposes like record-keeping, data governance, analyses of our products and services, risk analysis, and for conducting data analytics in general, as well as in connection to the oversight and management of the security and resilience of our networks, systems, and physical premises.
2.4. Processing Activities, Profiling and Tracking
In line with the Processing of your Personal Information for the purposes listed above, we conduct different sets of tasks (“Processing Activities”) that are required to provide you information, products, and services. Those Processing Activities dictate the Personal Information we collect, use, and disclose.
The following table highlights some of our Processing Activities and the categories of Personal Information we process or may process (depending on the context) pursuant to each Activity.
Note that Processing Activities and Personal Information collected, used, and disclosed may change occasionally.
Processing of Personal Information is required for administration of commercial electronic messages, administration of marketing campaigns, creation and distribution of marketing materials, management of leads, data acquisition, and administration of websites and information assets where your Personal Information is processed.
Name, email, phone number, age, country and province, type of investor, role, place of work, preferences (contact method, language), social media information (where linked by you), user activity (information about your interaction with our systems or social networks), personal testimonies, metadata.
Sensitive categories: Revenue (where personal), Range of investment (where personal).
Processing of Personal Information is required for conversion of leads, equity raise campaigns, preparation of purchase documents, administration of client requests, administration of client portal, change management pertaining to client requests related to redemptions, distributions and transfers, and investor verification*
In addition to Personal Information collected for marketing administration purposes, these processing operations require date of birth, suitability criteria (experience with investment products), product or service of interest, name and contact information of trusted contact person; information required in connection with the subscription agreement such as signature of subscriber or authorized person, beneficial subscriber contact information; and requests, and information provided by you.
Sensitive categories: Personal opinions, tax details, social insurance number, government IDs, credit check information, investment commitment, monthly income and expenses, marital status, number of dependents, details on financial and non-financial assets, sources of wealth, savings, applicable investment exemptions, statement of risk acknowledgement including risk of loss, existing non-registered investments, qualification as politically exposed person (PEP) or associated person, method of account opening and communication, source of client wealth, origins of investment funds, ties to high-risk jurisdictions, level of cash business activities, investment objectives and goals, insider and investing status, beneficial ownership and control, purchase date, transaction type, projected time of investment, information required to set up a trust account, and bank account details.
Operations Management and Finance
Processing of Personal Information is required for administration of client requests, administration of client portal, management of transactions, administration of payments and distributions, purchase management, and distribution of statements.
All of the Personal Information outlined in the Sales Administration Section.
Processing of Personal Information is required for oversight of investment operations, marketing, sales, financial and client reporting, management of conflict of interests, due diligence, legal and regulatory disclosures, and as otherwise needed to ensure compliance with different laws, regulations, and instruments applicable to us.
All of the Personal Information outlined in the Sales Administration Section.
Other Information of Relevance
The Processing Activities identified above require communication and sharing of Personal Information within the Skyline Group of Companies. For example, the financial component of your business relationship with us requires sharing Personal Information with Skyline Group of Companies’ finance department.
Profiling means the collection and use of Personal Information to assess specific characteristics of an individual, in particular to analyze that person’s work performance, economic situation, health, personal preferences, interests, or behavior.
We use the information you provide to understand your marketing preferences and document your investor profile. Compliance with some legal or regulatory requirements may result in you being profiled; that is the case when complying with AML/ATF, and KYC requirements, where we build your profile with information obtained from trusted sources to establish whether a business relationship or specific transaction should proceed. Note that we do not automate the profiling of individuals; there is significant human oversight of this process.
For clarity, your profile is created with information you share regarding your risk appetite and additional investment details. This is required for us to understand your needs and ensure that the product or service we offer aligns with your risk preferences.
Regarding marketing, we document your preferences, such as information, products, or services you may be interested in. You can always opt-out from our marketing communications by using the link available in emails you receive from us or by contacting us at email@example.com
2.5. Sharing Personal Information
- Service Providers: We use service providers for different purposes. We require them to abide by applicable legislation and implement security controls to safeguard your Personal Information.
Some of the categories of service providers with whom we share your Personal Information include marketing management, advertising partners, as well as technology vendors, analytics providers, credit bureaus, consultants, auditors, and record-keeping providers.
In addition to service providers, you have relationships with third parties with whom we need to exchange your Personal Information for processing transactions. Moreover, where you express interest, we will connect you to our partners for the provision of additional products or services, in which case disclosure of Personal Information will be required.
- Other Companies within the Group: If we determine that Processing of Personal Information by another entity within the Skyline Group of Companies would allow us to provide the service or product in a way that guarantees a better user experience for you, or where the expertise required to deliver you products or services lies with other entity within Skyline Group of Companies, we will grant them limited access, on a need-to-know basis, to the Personal Information they require to do so.
- Government Bodies or Authorities, Courts, Police, and Compliance with Legal or Regulatory Obligations: Where required to disclose information per legal or regulatory requirements; asked to comply with an order or similar request, or to collaborate on matters subject to investigation, we will disclose your Personal Information to the extent permitted by law or, where available, in line with applicable case law (like court, tribunal, board, or commission decisions) when no law regulates the order or request. In addition, we will disclose your Personal Information when necessary to comply with legal or regulatory obligations.
- Access Requests by Third Parties: In some cases, third parties submit requests for access to Personal Information which are processed in accordance with parameters provided by the law.
3. Storage of Data, International Transfers and Transfers Outside of Quebec
Your Personal Information may be processed outside of Canada. If you are a Quebec resident, please be advised that your Personal Information is processed outside of Quebec.
Personal Information may be accessed, transferred, or transit through other countries due to the nature of the Internet and based on the hosting location of some of our service providers. Access from other countries may also be required for maintenance, security, or support management.
4. Retention of Personal Information
We will keep your Personal Information for the period required to provide you with products or services and for a more extended period where required or authorized by law, regulation, or guidance.
We understand that the security of your Personal Information is essential; because of that, we employ a range of prevention and detection tools and methods to safeguard against the loss, unauthorized access, and unauthorized disclosure of the Personal Information we hold. Additionally, we implement administrative measures, such as contractual provisions, to ensure that the parties we share your Personal Information with are subject to legal and technical requirements to protect it.
6. Your Rights
You are entitled to access and rectify the Personal Information we hold about you. If you are a Quebec resident, you may be entitled to additional rights. To exercise these rights, please use one of the following mechanisms:
- Privacy Right Request form available on our website
- Email: firstname.lastname@example.org
- Mail: Please direct your communication to
Co-founder, Chief Administrative Officer & Privacy Officer
Attention: Legal - Privacy & Data Security
301 - 5 Douglas St,
In connection to the exercise of your rights, we reserve the right to communicate with you to verify your identity and relationship with Skyline Wealth Management, respond to questions you may have during the process, follow up with you and clarify the boundaries of the request where necessary, and to let you know about the progress of your request.