SciVest Capital Management Inc.

 

Privacy Policy

How we collect, use, protect and disclose your personal information

 

Version 2.0 · Effective August 10, 2026

Published in accordance with the Personal Information Protection and Electronic Documents Act (Canada) and applicable provincial private-sector privacy laws


1. About this Privacy Policy

SciVest Capital Management Inc. (“SciVest”, “we”, “our” or “us”) is a discretionary portfolio manager that carries on business under the registered operating names SciVest, SciVest Direct, SciVest Private Wealth Partners and SciVest Institutional Solutions. We recognize how important privacy is to our clients, prospective clients and the other individuals we deal with, and we are committed to protecting the personal information entrusted to us. This document (our “Privacy Policy”) describes how we collect, use, disclose, retain and protect personal information, and the choices and rights you have, in accordance with the federal Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), Alberta’s Personal Information Protection Act and British Columbia’s Personal Information Protection Act, as applicable, and any other privacy law that applies to our activities.

This Privacy Policy applies to the personal information of: (i) SciVest clients and prospective clients, and their representatives, agents, joint account holders and beneficial owners; (ii) visitors to our website(s) and social media pages and users of the SciVest client portal (the “Client Portal” and of our SciVest-branded secure client document upload portal (the “Upload Portal”)); (iii) individuals who request information from us, subscribe to our communications or attend our presentations, webinars or other events; and (iv) any other individuals from whom we collect personal information in the course of our business activities.

The most recent version of this Privacy Policy is posted on our website and to the Client Portal, and a copy is provided to each client with their account-opening documents. This Privacy Policy is notice of our personal-information practices. By providing personal information to us or using our services, website or Client Portal, you acknowledge those practices. Where consent is required, we obtain express or implied consent appropriate to the sensitivity of the information and the reasonable expectations of the individual. Posting an updated policy or continued use of a service does not, by itself, authorize a materially new collection, use or disclosure where additional consent is required by law.

2. What is Personal Information?

Personal information is information about an identifiable individual, including information that can reasonably be linked to an individual. In our business it typically includes your name, address and contact information, date of birth, government-issued identifiers (such as your social insurance number or other tax identification numbers), employment and financial information, banking and account information, the know-your-client (“KYC”) information we collect about your financial circumstances, investment knowledge, objectives, risk profile and time horizon, your account holdings and transactions, preferences and inferences derived from information about you, and your communications and interactions with us (including, where applicable, the recordings, transcripts, notes and summaries described in Section 5). It also includes certain technical and usage information collected when you use our website, our emails or the Client Portal (Section 10).

Personal information generally does not include business contact information used solely to communicate with an individual in their business capacity. Information that has been aggregated or de-identified may still be treated as personal information where there is a reasonable possibility that it could be re-identified. Information rendered irreversibly anonymous so that it can no longer reasonably identify an individual is not personal information.

3.  What we collect and where it comes from?

Most of the personal information we hold is collected directly from you, through: account-opening and other forms, questionnaires and agreements (including your Investment Management Agreement (“IMA”), KYC questionnaire and Investment Policy Statement, generally completed and signed electronically through Docusign); meetings, telephone and video calls, email and other correspondence and interactions with us; the documents you provide to verify your identity or submit through the Upload Portal; messages you send us through the Client Portal’s contact feature; and your requests for information or educational materials, subscriptions to our communications, and attendance at our presentations, webinars and other events.

We also collect personal information from third parties where needed to serve you or as permitted by law, including from: your custodian, executing brokers and other financial institutions (for example, when your accounts are opened, funded, transferred or administered); our identity-verification, anti-money-laundering (“AML”), sanctions and fraud-screening providers; if you are a SciVest Private Wealth Partners client who was referred to us, the person or firm that referred you (your “Referrer”), in accordance with the referral-arrangement disclosure and authorization provided to you; joint account holders; and the professional advisors and agents you authorize to deal with us.

If you provide us with personal information about another individual – for example, a spouse, joint account holder, beneficiary, trustee, director or authorized agent – you must have lawful authority to provide that information and, where consent is required, must have obtained that individual’s consent to our collection, use and disclosure of their personal information for the purposes described in this Privacy Policy.

Finally, we automatically collect certain technical and usage information when you use our website, open or interact with our emails, or use the Client Portal, as described in Section 10. 

4.  Why we collect personal information?

We collect, use and disclose personal information for the following purposes:

  • to verify your identity, authenticate instructions, protect against fraud, and meet our obligations under AML, sanctions and anti-terrorist-financing legislation;

  • to understand and keep current your financial circumstances, needs and objectives and to meet our KYC, suitability and related securities-law obligations;

  • to open, administer and operate your accounts, manage your portfolio on a discretionary basis, execute and settle transactions, transfer accounts and assets, and provide statements, reports, tax documents and other client communications;

  • to communicate with you about your accounts and our services – by mail, email, telephone, video conference, text message or, where necessary, fax – to authenticate and act on instructions, and to respond to inquiries;

  • to establish authorized household or related-account groupings and provide consolidated or household reporting where you have requested or authorized it;

  • to administer, supervise and document referral arrangements, including providing authorized relationship support and account reporting and calculating, verifying and disclosing referral compensation, where applicable;

  • to comply with our legal, regulatory, tax, audit, books-and-records, reporting and supervisory obligations, and to respond to lawful requests from regulators, taxation authorities, courts and law enforcement;

  • to detect, prevent and investigate fraud, security incidents, errors and unlawful activity; manage business, operational and cybersecurity risk; and handle complaints, disputes and legal claims;

  • with your consent, to provide newsletters, educational materials, invitations to presentations and other events, and information about SciVest’s services;

  • to operate, test, improve and secure our website, Client Portal, technology, business processes and services, and to create aggregated or de-identified analytics for internal planning, service improvement and risk management, subject to applicable law.

We do not sell, rent, trade or lend your personal information. We collect only the personal information that is reasonably necessary for the purposes identified at or before collection, or for other purposes permitted or required by law. 

5.  Recording, transcription and artificial-intelligence tools 

We may record telephone calls, video conferences and in-person meetings with you or your authorized representatives, and may transcribe, summarize and generate notes from those communications. We may use third-party videoconferencing, telephony, recording and artificial-intelligence transcription, summarization and note-taking services for these purposes – usually services available through the Zoom platform operated by Zoom Communications, Inc. (“Zoom”). Recordings, transcripts, notes and summaries may be used to document KYC, suitability and other regulatory obligations, for supervision and quality assurance, for complaint handling and dispute resolution, and for maintaining required books and records. Notice of recording and of any artificial-intelligence features in use is generally provided through the platform’s in-meeting notifications or verbally, although notice may not be given in every instance. We are under no obligation to record any communication.

Recordings, transcripts, notes and summaries form part of your personal information and are handled in accordance with this Privacy Policy and applicable law. Artificial-intelligence tools assist with documentation; SciVest personnel remain responsible for reviewing material outputs and for all KYC, suitability, portfolio-management and supervisory decisions. We do not use these meeting-documentation tools to make solely automated investment or suitability decisions about you. Where provider controls are available, we use settings and contractual protections intended to prevent client content from being used for the provider’s independent purposes, including training general-purpose artificial-intelligence models. Before enabling a material new artificial-intelligence function that would use personal information for a new purpose or create a material new risk, we assess the privacy implications and provide additional notice or obtain consent where required.

Where a service provider offers Canadian data residency, we configure our accounts to store applicable content in Canada where practical – as we currently do with Zoom for eligible recordings, related content and live-transcript processing. Some account and operational data, transient processing, support functions and artificial-intelligence processing may nevertheless occur in the United States or other jurisdictions, including through provider subprocessors. Information processed outside Canada may be accessible to courts, law enforcement, regulators or national-security authorities under the laws of those jurisdictions. You may decline the recording or artificial-intelligence transcription of a particular communication by advising us, in which case we will document the communication by other means. You should not assume that any communication has been recorded or retained.

6.  Consent and how to withdraw it 

We collect, use and disclose personal information with your consent or as otherwise permitted or required by law. Consent may be express – for example, when you sign your IMA, a referral authorization or another agreement or form, or agree to a recording after receiving notice – or implied where the information is less sensitive, the purpose is obvious and the circumstances support implied consent. We seek express consent where required by law, where the information or activity is sensitive, or where the collection, use or disclosure would not reasonably be expected.

You may withdraw a consent at any time, subject to legal and contractual restrictions and reasonable notice, by contacting our Chief Compliance Officer, who is also our privacy officer (our “Privacy Officer”; contact details are in Section 14). We will explain the reasonably foreseeable consequences of withdrawal. Withdrawing consent may limit or prevent our ability to provide services to you: some collection, use and disclosure – including identity-verification, KYC, suitability, account-administration and regulatory recordkeeping – is necessary to open and maintain an account. Withdrawal does not affect handling that was lawful before withdrawal and does not require us to delete information that we must or are permitted to retain.

You may opt out of marketing communications at any time without affecting service, regulatory or security communications about your accounts. Our commercial electronic messages include an unsubscribe mechanism in accordance with Canada’s anti-spam legislation, or you can contact our Privacy Officer. Where a collection, use or disclosure is optional and not necessary to provide the requested service, we provide a reasonable choice where required by law.

7.  Who we disclose personal information to? 

We disclose personal information to third parties only as needed to serve you, with your consent, or as required or permitted by law, including to:

  • your custodian and executing brokers (currently one or more of NBIN, IBKR and Aviso, as identified in your account-opening documents), to open, fund, transfer and operate your accounts and to execute, clear and settle transactions;

  • service providers who assist us in operating our business, such as our portfolio-management-system and Client Portal provider (currently Infinite Investment Systems Ltd.) and trading, pricing and data vendors; identity-verification, AML, sanctions and screening providers (currently including Canchek Corporation); electronic-signature providers (currently Docusign, Inc.), secure document-storage, file-transfer and cloud-service providers (currently including Sync.com Inc. and Dropbox); our email and office-productivity provider (currently Microsoft Corporation, whose Microsoft 365 services include Exchange Online for email); cybersecurity, information-technology, backup and business-continuity providers; videoconferencing, telephony, recording and artificial-intelligence transcription and note-taking providers (usually the Zoom platform); our website, customer-relationship-management, analytics and email-marketing platform (currently HubSpot); and our accounting, audit, legal, tax and other professional advisors;

  • if you are a SciVest Private Wealth Partners client, your Referrer, where applicable and as authorized and described in the referral-arrangement disclosure provided with your IMA. Information shared is limited to what is reasonably required to support and administer the relationship and referral arrangement and may include your identity and contact information, relationship status, referral-compensation information and read-only account or household reporting. A Referrer does not obtain authority to trade, change your instructions or make KYC or suitability decisions by receiving this information. SciVest remains responsible for discretionary portfolio management, KYC and suitability;

  • joint account holders and, where authorized, members of a household or related-account group. Information about a joint account is available to each account holder, and consolidated or household reporting may allow an authorized recipient to see or infer information about other included accounts;

  • your professional advisors, agents and other persons you authorize to receive information about you or your accounts, subject to the scope of your authorization;

  • taxation authorities, securities regulators and other regulatory bodies, law enforcement, courts and other persons where disclosure is required or permitted by law, including to establish, exercise or defend legal claims; and

  • the parties to, and advisors involved in, a prospective or completed sale, transfer, reorganization, financing, merger or similar transaction involving all or part of our business or assets, subject to legal and contractual confidentiality and use restrictions. If a transaction is not completed, we require the recipient to return, destroy or cease using the information as appropriate; if completed, personal information will continue to be handled in accordance with applicable law and the commitments communicated to you.

Our agreements with service providers generally require them to use personal information only for authorized purposes, to protect its confidentiality and security, to notify us of material incidents and to return or securely dispose of information when appropriate, subject to legal retention requirements. We assess service providers having regard to the sensitivity of the information and the services involved, and use contractual and other measures intended to provide a level of protection comparable to that required of us. We remain accountable for personal information transferred to a service provider for processing on our behalf.

8.  Where personal information is stored and processed?

Your personal information is maintained on our systems and on the systems of our service providers. It may be stored or processed in Canada, the United States and, in some cases, Europe. Where a service provider offers a practical choice of storage location, our preference is always Canadian storage, and we do not typically use providers that store personal information outside Canada, the United States or Europe; however, Canadian storage is not available for every service or function, and account, operational, support, transient-processing or artificial-intelligence data may be processed outside Canada. Much of our core client information nevertheless has Canadian residency: our portfolio-management system (Harmony) and the Client Portal, both provided by Infinite Investment Systems Ltd., are hosted on secure servers in Canada and hold your account data and most client documents; our client records – including copies of identification, account agreements, KYC documentation, investment policy statements, transfer, custody and account documents, and investment statements – are stored with Sync.com Inc., a Canadian provider whose servers are located in Canada and whose service applies end-to-end encryption; and our Docusign electronic-signature workflows – including the exchange of information with our portfolio-management system – are configured for Canadian data residency, with completed documents retained by Docusign only for a limited period before we transfer signed documents to our Canadian client-records storage. Our email and office-productivity environment is hosted on Microsoft 365, for which Microsoft commits to store Exchange Online, SharePoint, OneDrive and Teams customer data at rest in Canada. Our general corporate cloud-storage service (currently Dropbox) is used for business materials rather than client records and stores files in the United States.

Personal information outside Canada is subject to the laws of the country where it is processed and may be accessible to foreign courts, law enforcement, regulators or national-security authorities. We assess material service providers and use contractual, technical and organizational measures intended to require comparable protection and limit processing to authorized purposes. You may contact our Privacy Officer for current written information about the countries outside Canada in which service providers may collect, use, disclose or store personal information and the purposes for which those providers are authorized to process it.

9.  How we protect personal information; retention and accuracy 

We protect personal information with physical, organizational and technological safeguards appropriate to its sensitivity and the reasonably foreseeable risks. Depending on the system and information involved, these safeguards may include restricted premises access, role-based access controls, multi-factor authentication, secure configuration, encryption in transit and at rest, logging and monitoring, malware protection, secure backups, employee confidentiality obligations and training, service-provider due diligence, incident-response procedures and secure disposal. We limit access to people who require it to serve you or operate our business. No security measure can eliminate all risk, and we review and update our safeguards as circumstances and threats evolve. When responding to a legal or regulatory demand, we take reasonable steps to confirm its validity and disclose only the information required or permitted.

Please treat email and electronic communications with care. Ordinary email may not be a secure means of sending sensitive personal information, and information sent by unencrypted email may be intercepted or misdirected. Use the secure delivery methods we make available or recommend – such as Docusign for completing and signing documents, or the Upload Portal for sending us identification and other sensitive documents – when we ask you to do so, and keep your Client Portal and custodian-portal credentials, devices and authentication codes confidential. Notify us promptly if you suspect unauthorized access to an account or communication channel.

We retain personal information only as long as reasonably necessary for the purposes for which it was collected, to provide and document our services, and to meet legal, regulatory, tax, accounting, complaint-handling and dispute-resolution obligations. Securities legislation requires many of our books and records, including client records, to be retained for at least seven years from creation, and some information may be retained beyond the end of your relationship with us. We also preserve information that is subject to an access request, investigation, legal hold or unresolved complaint. When personal information is no longer required, we securely destroy, delete or irreversibly anonymize it, subject to ordinary backup and archival cycles and legal restrictions.

We make reasonable efforts to keep personal information accurate, complete and up to date for the purposes for which it is used. You can help by promptly notifying us of changes to your contact, financial, tax, beneficial-ownership or KYC information. If you identify an error, we will correct it where appropriate; if a requested correction is not made, we will note the request or disagreement as required by applicable law.

10.  Website, cookies and analytics 

Our website is currently hosted on the HubSpot platform, and we use HubSpot’s customer-relationship-management, marketing and analytics tools in the operation of our website, emails and marketing campaigns. Like most business websites and electronic communications, our website and emails may collect technical and usage information – such as your IP address, browser and device type, approximate location, the pages you visit, links you select, form interactions, and whether and when you open an email – using cookies, log files, tracking pixels and similar technologies. We use this information to operate, protect and troubleshoot the website; understand how our website and communications are used; measure and improve content and campaigns; remember preferences; and follow up with individuals who have expressed interest in our services. We may also use other analytics tools, such as Google Analytics, for similar purposes.

You can manage cookies through any cookie-preference tool presented on our website and through your browser settings. Where required by applicable law, we seek your choice before using non-essential analytics, personalization or marketing technologies. Essential cookies may be required for security, authentication and core website or portal functionality. Disabling cookies or similar technologies may affect functionality and may not block every technology, including certain email pixels. You can opt out of marketing emails as described in Section 6.

The Client Portal, provided through Infinite Investment Systems Ltd., gives you read-only access to your account documents, monthly investment statements, reports, holdings and performance information, includes links to custodian websites, and provides a facility for sending messages to us. It is not used to submit documents or to make changes to your account information. To send us sensitive documents securely – such as copies of identification or investment statements from other financial institutions – please use our SciVest-branded Upload Portal, administered by Sync.com Inc. and protected with end-to-end encryption, rather than email.

Our website may contain links to external websites, applications or portals, including those of custodians and other service providers. This Privacy Policy does not apply to third-party services that SciVest does not control, and we are not responsible for their content, security or privacy practices. Review the third party’s privacy information before providing personal information or connecting an account.

11.  Social media 

We are active on social media, and we invite you to engage with our content. The social media platforms we use are, however, independent of SciVest, and anything you post publicly on our pages can be seen by anyone who visits them. Please do not share sensitive personal information on our social media pages or through social-media private messages (beyond the limited information needed to identify and contact you). If you engage with our content, we may collect information associated with your social media account, such as your name, username and profile information. We reserve the right to remove posts that contain personal information, personal attacks or defamatory, abusive or hateful comments, or spam or links to unrelated or potentially malicious content.

12. Your rights: access and correction 

Subject to applicable law, you may request: confirmation of whether we hold personal information about you; access to that information; information about how it has been used and disclosed; and correction of inaccurate or incomplete information. Requests should be made in writing to our Privacy Officer and provide sufficient detail to locate the information. Before responding, we may verify your identity and authority, and we will not request more verification information than is reasonably necessary. Access is subject to exceptions permitted or required by law, including information that would reveal personal information about another person, confidential commercial information, information protected by legal privilege, or information whose disclosure could threaten another person’s life or security.

We respond within the period required by applicable law – generally within 30 days under PIPEDA and British Columbia’s Personal Information Protection Act, and within 45 days under Alberta’s Personal Information Protection Act – subject to any permitted extension. If we extend the period or refuse all or part of a request, we will provide the notice, reasons and recourse information required by law. Where a fee is permitted, we will provide an estimate before incurring it. You may also challenge the accuracy and completeness of personal information and request an appropriate correction; where information remains in dispute, we will note your position as required.

13. Data Breach 

If a breach of security safeguards involving personal information creates a real risk of significant harm, we will report it to the applicable privacy regulator or regulators – which may include the Office of the Privacy Commissioner of Canada and the Office of the Information and Privacy Commissioner of Alberta – and notify affected individuals as soon as feasible or without unreasonable delay, as required by applicable law. A notification will contain information reasonably needed to understand the significance of the breach and take available steps to reduce or mitigate harm. We may also notify another organization or government institution that can help reduce or mitigate harm. We maintain records of breaches of security safeguards as required by law and use incidents to improve our safeguards and response procedures.

14.  Questions, concerns and complaints  

If you have any questions or concerns about this Privacy Policy or the confidentiality of your personal information, wish to access or correct your personal information, wish to withdraw a consent, or wish to make a privacy complaint, please contact our Privacy Officer:

Dr. John J. Schmitz, Chief Compliance Officer and Privacy Officer
SciVest Capital Management Inc., 264 Central Avenue, London, Ontario, N6A 1M8
+1 519-679-7979

We will acknowledge and investigate privacy complaints and respond within a reasonable time. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada (www.priv.gc.ca; 1-800-282-1376) or, where provincial private-sector privacy law applies, the Office of the Information and Privacy Commissioner of Alberta (www.oipc.ab.ca) or the Office of the Information and Privacy Commissioner for British Columbia (www.oipc.bc.ca). The regulator with jurisdiction will depend on the circumstances, location and nature of the personal-information handling involved.

15.  Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in law, technology, service providers or our practices. When we do, we will post the updated version to our website and to the Client Portal, and update the version number and effective date. We will bring material changes to your attention in an appropriate manner and, where required by law, obtain consent before applying a materially new collection, use or disclosure. Posting an updated Privacy Policy or continued use of a service does not retroactively authorize a new purpose where additional consent is required. We will continue to handle personal information consistently with the commitments in effect when it was collected, unless you consent otherwise or the law requires or permits otherwise.

SCIVEST CAPITAL MANAGEMENT INC.