Northwood Family Office Ltd.
(hereafter referred to as âNorthwoodâ)
This Privacy Policy applies to the operations of Northwood Family Office. It applies regardless of how you communicate with us â over the phone, in person, through the internet, through your mobile device or through email.
We are dedicated to respecting and protecting the privacy and confidentiality of the information you have entrusted to us. Our Privacy Policy outlines our privacy principles and practices.
The Notice applies to any person who communicate with us, regardless of the means used, and any individual whose personal information we collect in carrying out our business activities including,
⢠Investors and Account Holders
⢠Financial Services Professionals
⢠Visitors to Our Office
⢠Event Attendees
⢠Website, Mobile Applications and Social Media Users
Personal information refers to information that identifies you. We collect personal information directly from you or indirectly through someone you authorize or from third parties in accordance with applicable law.
The information that we collect or receive from you or other depending on the nature of your relationship with us. Â To learn about the collection practices that relate to you please click on the relevant categories that apply to your relationship with us below:
We collect information directly from you or from your authorized representative(s). Depending on how you do business with us, this information may be collected on applications, forms, over the phone, in person, through the internet, through your mobile device or through other forms of communication. Â We also collect information about you indirectly where permitted by law. Â We limit the collection of information to what is necessary to fulfill the purpose for which the information is collected.
The information we collect includes,
⢠Contact Information, including name, address, telephone number, and email address
⢠Date of birth to help us identify and authenticate you
⢠Financial Information including bank account information to facilitate deposits and withdrawals from your account with us. When required we also use your financial information including your assets and liabilities, income and investment holdings to ensure that products, services, and advice we provide are appropriate for you and the investments you make are suitable for you.
⢠Employment Information to open accounts and in order to comply with anti-money laundering and other regulations
⢠Meeting Recordings, we may monitor or record meetings with you to ensure  service quality, for training purposes, and to accurately capture notes and action items.. We will notify you if a meeting will be recorded and you are able to decline.
⢠Email Information, when you send us an email or ask us to respond to you by email, we learn your exact email address and any information included in the email. We use your email address to reply to you and we will store your communication and our reply in case we correspond further. IMPORTANT: We will not ask you to provide personal information or login information, such as username, passwords, PINs, security question and answers or account numbers, through unsolicited email. If you receive an email claiming to be from us that you believe to be fraudulent, do not respond and do not open or click any links or open attachments contained in the email. Please notify us immediately and then delete the email.
⢠Website and Mobile Applications Use: when you choose to use our website or mobile application we collect information about your use of these services, please refer to our Online and Mobile Privacy Policy for details.
⢠We collect information directly from you or from your authorized representative(s). Depending on how you choose to do business with us, this information may be collected on applications, forms, over the phone, in person, through the internet, through your mobile device or through other forms of communication.  We also collect information about you indirectly where permitted by law.  We limit the collection of information to what is necessary to fulfill the purpose for which the information is collected.
⢠Contact Information, including name, address, telephone number, and email address to facilitate communications with you about your business.
⢠Provincial Securities Registration Status Information to determine categories and status of registration with provincial securities commissions and self regulatory organization.
⢠Audio Recordings, when we monitor or record incoming or outgoing telephone calls with you to ensure accuracy, security, service quality, for training purposes, and to establish a record. If you do not wish to have your call recorded, you have other options to conduct business with us, such as in person, online, or by communicating with us in writing
⢠Email Information, when you send us an email or ask us to respond to you by email, we learn your exact email address and any information included in the email. We use your email address to reply to you and we will store your communication and our reply in case we correspond further. IMPORTANT: We will not ask you to provide personal information or login information, such as username, passwords, PINs, security question and answers or account numbers, through unsolicited email. If you receive an email claiming to be from us that you believe to be fraudulent, do not respond and do not open or click any links or open attachments contained in the email. Please notify us immediately and then delete the email.
⢠Website and Mobile Applications Use: when you chose to use our website or mobile application we collect information about your use of these services, please refer to our Online and Mobile Privacy Policy for details.
Video Recordings or Photographs, as we may use video or photo surveillance in and around our offices for the safety of our clients and employees, and to protect against theft, property damage, and fraud.
⢠Contact Information, including name, address, telephone number, and email address to facilitate communications with you about your business.
⢠Attendance Information, including the events that you have participated in, the date, time and location of your attendance in order to provide you with professional accreditation certificates of training or event participation.
⢠Responses to Surveys, Feedback, Contests, or other activities we sponsor, 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 event, or improving our events, 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.
⢠Video Recordings or Photographs, as we may use video or photo surveillance in and around our offices for the safety of our clients and employees, and to protect against theft, property damage, and fraud.
⢠Social Media, when communicating with us through social media, we may monitor or record our discussions to maintain a record of the interaction, to enhance client service, and to confirm our discussions with you.
We may amend this Policy from time to time. When we make changes, we will post the revised Privacy Policy on our website and will inform individuals of any material updates through appropriate means, such as email notifications, website banners, pop up messages, or other clear methods designed to bring the changes to their attention.
The Privacy Policy 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 are accountable for the personal information under our control by establishing, training our staff in, and enforcing our privacy policies and procedures to promote compliance with these privacy principles. We have designated a privacy officer, our Chief Compliance 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 Chief Compliance Officer.
We have strict policies and procedures governing how we deal with your personal information, including the retention and destruction of personal information, the roles and responsibilities of our personnel in the handling of personal information and procedures for handling complaints regarding our protection of personal information. Every employee is responsible for respecting and protecting the personal information to which the employee has access.
We inform you about the purposes for which we collect, use, and disclose your personal information and we collect, use, and disclose your personal information only for those purposes.
We collect, use and disclose personal information only for the purposes for which it was collected. When we collect personal information, we use it to:
⢠Open and operate your account,
⢠Verify your identity,
⢠Execute transactions you request,
⢠Record account information and report account status back to you,
⢠Respond to any request or questions you may have,
⢠Provide you with quality personalized service and support
⢠Determine suitability of products and services,
⢠Determine your eligibility for certain of our products and services, or products or services of others
⢠Communicate with you about products and services that may be of interest,
⢠Market and advertise our products and services,
⢠Conduct internal research and data analytics, including effectiveness of digital marketing,
⢠Anonymize data or create aggregated datasets, such as for consolidating reporting, research, or analytics
⢠Provide all required tax reporting,
⢠Comply with legal, regulatory, and contractual requirements, or as otherwise permitted or required by law
⢠Fulfill obligations under federal anti-money laundering and suppression of terrorism legislation,
⢠Protect our interests, including recovering any debts you may owe us,
⢠Protect against fraud and other crime and to manage risk, including conducting investigations and proactive crime prevention measures
Your personal information will also be used for purposes named in your respective application forms and account agreements. Â
If a new purpose for using your personal information develops, we will inform you of that purpose.
We obtain your consent to collect, use, or disclose personal information and you may at any time revoke that consent, subject to legal and regulatory requirements. In some cases, we may not be able to provide certain services to you if you do not consent or withdraw consent to our collection, use or disclosure of the required information to perform those services.
If you have any questions or require assistance understanding the scope of the consent we request from you, please Contact Us.
Depending on the type and sensitivity of the personal information and the way you interact with us (in person, internet, phone, email, etc.), we may obtain your consent in different ways.
⢠We may obtain your express consent verbally, online, or in writing. For instance, when we collect your information via our account application form, you will formally indicate your consent for us to collect and use the information when you sign the application.
⢠We may, however, get your implied consent through your use of a product or service, or when you approach us to obtain information, inquire or apply for products or services from us.
⢠Also, we may obtain consent directly from you or by your authorized representative(s).
You may withdraw your consent for the collection, use and disclosure of your personal information at any time by forwarding a written request to the Chief Compliance Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us.
However, there are certain times when you may not withhold or revoke your consent including certain legal, regulatory, or contractual requirements.
We must receive reasonable notice of your request in order to honour your consent withdrawal.
Your decision to withhold or revoke your consent may limit the products and services that we may provide to you and may require you to close your accounts with us.
We limit collection of your personal information to that which we determine is necessary for the purposes we identify for you.
We only collect the personal information we determine we need for our identified purposes.
We do not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as required by law.
We only use or disclose your information for the purpose(s) it was collected and as otherwise identified in this Notice
We do not sell or rent client lists or personal information to third parties.
Our employees or authorized representatives, who are responsible for functions relevant to the purposes identified within this notice, and other persons authorized by you or by law, will have access to your personal information. Â Our employees and authorized representatives are required to maintain the information in the strictest of confidence and do not provide access to the information to anyone who is not authorized.
To protect our interests
We may disclose information to any person or organization, including an investigative body, in order to prevent, detect or suppress, financial abuse, fraud, criminal activity, protect our assets and interests, or manage or settle any actual or potential loss or in the case of a breach of agreement or contravention of law. We may also disclose information to help us collect a debt owed to us
In the event of a transfer of a business
We may buy or sell a business (or evaluate those transactions) which would result in certain personal information forming business assets that would be purchased or sold as part of a transfer. We may also transfer personal information as part of a corporate reorganization or other change in corporate control
In other situations where we have your consent
For instance, sharing your information with your authorized representative(s) or a joint account holder.
To third party service providers for servicing purposes
We disclose to them only such personal information as they need to perform the services. We do not authorize them to use or disclose the personal information for their own marketing or other purposes. Third party service providers may include, but are not limited to, custodians, fund managers, accountants, lawyers, and other parties as required. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. They may be located in Canada or other jurisdiction or countries and may disclose information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries in accordance with the applicable law in that jurisdiction or country. For more information on our third party service providers, including where they are located, please Contact Us.
To your legal representatives
We disclose information upon your request or in accordance with the authority that you have provided these legal representatives, such as an individual that you have granted power of attorney and/or trading authority.
To your financial institutions, portfolio managers, and securities issuers
We disclose information to comply with your requests, such as transfer of funds to your banking institution or external another dealership or fund manager.
To CI Financial company affiliates
We share personal information among any of the subsidiaries and affiliated companies that comprise CI Financial Corp. who perform administrative services for us
To governments, government agencies, regulators, including self-regulators
We share personal information when required or permitted to do so by law, including in response to a search warrant, court order, or other demand or inquiry which we believe to be valid
Information may be transferred to, accessed and/or retained by these third parties. We may store your personal information via third party entities that reside in foreign jurisdictions. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. We and/or a third party may be compelled, by law or otherwise, to provide information to a third party, subject to applicable privacy law. We must abide by applicable privacy law in the jurisdiction(s) in which we operate.
Your personal information is kept in electronic or paper format:
⢠In our offices
⢠In secure off-site storage facilities, or
⢠In the offices of our service providers
We have policies in place that govern the retention of your personal information, so we keep it only for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements. The length of time we keep your information will depend upon the product or service and the nature of the information.
When we no longer retain your personal information, we have procedures to destroy, delete, erase or convert it to an anonymous form, in a manner that keeps it safe in the process.
We maintain your personal information in as accurate, complete, and up-to-date form as is needed for its use.
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.
We maintain appropriate security safeguards to protect against unauthorized access, disclosure, copying, use or modification, theft, misuse, or loss of your personal information in our custody or control. These safeguards are appropriate to the sensitivity of the information.
We have policy and procedures in place which inform our employees, representatives, and agents of our and their responsibilities when collecting, using, and disclosing the personal information that we collect. Â We provide our employees with annual training on our privacy policy.
We maintain appropriate physical, electronic, technological, procedural, and organizational safeguards to protect against unauthorized access, disclosure, copying, use or modification, theft, misuse, or loss of your personal information in our custody or control. These safeguards are appropriate to the sensitivity of the information.
We have agreements in place with third party service providers requiring that personal information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the provider to perform.
Upon request, we will inform you of the existence, use and disclosure of your personal information and will give you access to that information, with few exceptions.
How can I access my personal information?
We encourage you to contact our Client Services department to correct or access your information on file with us. However, you do have the right, subject to certain limitations, to formally request to review or verify your personal information, or to find out to whom we have disclosed it. To make a formal request for access, send a written request addressed to the Chief Compliance Officer in Contact Us  below. Please include your full name, address, telephone number, and account number(s) on all correspondence to us and provide enough detail to allow us to identify the information you want and the details of the information that you are seeking.
Upon request, we will provide you with access to your personal information we have on record at the time of the request. Please note that we may not be able to provide you with this information in certain circumstances, for example without limitation, where such information:
⢠Contains references to other persons
⢠Contains proprietary information confidential to us
⢠Has been destroyed
⢠Is too costly to retrieve
⢠Is subject to legal or some other form of privilege
⢠Cannot be disclosed for legal reasons
⢠Relates to an investigation
If we are unable to provide some of the personal information, we hold about you, we will tell you why, when permitted by law.
We will advise you in advance if a minimal charge will be required for conducting the search and we will respond to your request within 30 days.
How can I correct my personal information?
If you discover inaccuracies in our records, or your personal information changes, please notify Northwood 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.
What other rights do I have?
You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us to use for your own purposes, or to lodge a complaint with a supervisory authority. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request. To exercise any of these rights, please contact us in writing using the contact information set out in the âContactâ section below.
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.
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. 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.
We collect personal information when you communicate with us through email or other electronic services (collectively, digital channels), including:
⢠Personal information you provide within our digital channels, such as account and contact information, including your name, email address, user ID, password, and service preferences. Information that you submit by email, including any attachments.
⢠Account Opening information â that you provide to us at the time of account set up.
⢠Voluntary Participation Information, such as any feedback you may provide us through our website.
We may use or disclose this information collected online to:
⢠Verify and authenticate your identity
⢠Provide you with services and recommendations
⢠Communicate with you, with your consent, regarding products and services that may be of interest, including displaying targeted and relevant advertising
⢠Tailor our services and otherwise enhance the online customer experience to better meet your needs
⢠Protect against fraud, security threats, and otherwise manage risks
⢠Satisfy legal or regulatory requirements
We may scan the email messages that you send to us to detect viruses, malware or other computer threats. We and our third-party service partners may use the information gathered about potential viruses, malware or other computer threats detected to improve the threat detection tools that we use. Our third-party service providers are required to keep the information confidential. Email messages identified as potentially containing a threat may undergo further analysis and any personal or financial information contained in the email message may be incidentally accessed by individuals investigating and addressing the threat.
Information about Canadaâs Anti-Spam Legislation
In order to ensure compliance with Canadaâs Anti-Spam Legislation, commercial electronic messages (including email marketing) will be based on an individualâs consent. We will request consent to send commercial electronic messages prior to sending commercial messages (including emails), unless we have an individualâs implied consent through a pre-existing business relationship. We provide individuals with the ability to unsubscribe from receiving promotional emails from our company, and/or Partners and Associates. Upon establishing an account with our online services, where available, you will be asked to choose your document delivery preferences. You will be sent notification e-mails when documents are added to your online account. We will also send you e-mail alerts when you make changes on your online profile.
You may choose to enter your information to participate in online meetings, webinars or 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.
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 âSecure Sockets Layerâ (SSL). SSL ensures that the information transmitted is encrypted. In addition, we use the concept of âdefense in depthâ, in our cybersecurity program that has many layers, from employee awareness to having firewalls at the very edge of our network.
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 Northwoodâs 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. Northwood will never send you unsolicited messages or emails asking for your password, credit card, account numbers, etc. Northwood will never ask you to validate or restore your account or access to the Services through unsolicited messages or emails.
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-Northwood websites are not subject to Northwoodâs privacy policy or security standards.
Northwood Family Office Ltd.
130 King Street West, P.O. Box 245, Suite 2250
Toronto, Ontario, M5X 1C8
Phone (416) 502-1245
Email: compliance @northwoodfamilyoffice.com
STEP 1: Voice your question or concern
The best way to address a concern or question is to contact Northwood as soon as it comes up by contacting them.
STEP 2: Escalate your concern to the Chief Compliance Officer
If our Service group are unable to address your concern or question you can escalate in the following ways:
⢠Ask the individual you are dealing with in Step 1 to escalate on your behalf.
⢠Escalate the concern directly with the Chief Compliance Officer, using the following contact information.
STEP 3: Further Escalation
If after contacting us you do not feel that your concern has been adequately addressed, you may wish to contact:
The Office of the Privacy Commissioner of Canada
Call: 1-800-282-1376
Visit: www.priv.gc.ca
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Last Update January 2026
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