Privacy Policy

Privacy Notice

This Privacy Notice explains the types of personal information Prime Quadrant US, LLC (“PQUS”) and Prime Quadrant Corp. (“PQ Corp,” and together with their respective affiliates, subsidiaries and parent companies, “Prime Quadrant,” “we,” “us” or “our”) collect, how it is used, to whom it is disclosed, how it is protected, and your legal rights. This Privacy Notice applies to our websites, online services and other interactions with visitors, users, clients, prospective clients and other individuals in the United States and Canada. “Personal information” means information that (either in isolation or in combination with other available information) enables you to be identified as an individual or recognized directly or indirectly, and includes “personal information” or “personal data” as defined under applicable U.S. and Canadian privacy laws. It would not include aggregate, anonymized or deidentified information or various types of publicly available information, in each case where excluded by applicable law.

In order to perform services for you, operate our websites and communicate with you, we will need to collect, maintain and utilize personal information about you.   We do not disclose your personal information to any third party for the purpose of allowing that party to market other products to you, except where permitted by law and subject to any choices described in this Privacy Notice. We maintain your information in confidence and do not share this information with any individual or entity unless that individual or entity has a need to access that information for the purpose of providing services to you or operating, securing, improving or legally administering our business and websites. While in our possession, your information is maintained with safeguards appropriate to the sensitivity of the information, and these systems and safeguards are reviewed periodically.  Various U.S. federal and state privacy laws and Canadian federal and provincial privacy laws, including the Personal Information Protection and Electronic Documents Act and substantially similar provincial private-sector privacy laws, require or inform the following additional disclosures regarding your personal information:

Use of Personal Information; Website Data; California Notice at Collection

In the first column below, for California residents, we have noted the corresponding category from the California Consumer Privacy Act of 2018, as may be amended or supplemented from time to time, including by the California Consumer Privacy Rights Act of 2020 (collectively, CCPA). These categories also describe the types of personal information we may collect from U.S. and Canadian website visitors and users, subject to applicable law.

Category of Personal Information   Representative Data Elements

Contact Information

[Contact Information may be categorized as “Identifiers,” “Education Information,” or “Personal Information” under the CCPA.]
  • Full name, nicknames, and previous names (such as maiden names)
  • Honorifics and titles
  • Mailing address
  • Email address
  • Telephone, mobile, and fax numbers
  • Contact information for related persons, such as authorized users of your account

Government-Issued Identification Numbers

[Government-Issued Identification Numbers may be categorized as “Identifiers” or “Education Information” under the CCPA.]
  • Social Security number
  • Driver’s license number
  • Passport number
  • Other government-issued identifiers as may be needed for compliance

Relationship Information

[Relationship Information may be categorized as “Inferences,” “Protected Classifications under California or Federal Law,” “Professional or Employment-Related Information,” or

“Education Information” under the CCPA.]
  • Personal characteristics and preferences, such as your age range, date of birth, gender, marital and family status, racial or ethnic origin, and language preferences
  • Communication and marketing preferences
  • Beneficiary information
  • Demographic data
  • Household demographic data, including from real estate records and census data
  • Data from social media profiles, such as Facebook, Twitter/X, LinkedIn, and similar platforms
  • Education information
  • Professional information

Transaction and Interaction Information

[Transaction and Interaction Information may be categorized as “Personal Information,” “Internet or Other Electronic Network Activity Information,” or “Commercial Information” under the CCPA.]
  • Client account information, qualification data, transaction history, instructions, and related records
  • Client service records
  • Non-biometric data collected for authentication or authorization (passwords, signatures, account security questions, data collected by premises monitoring devices)
  •  Communications with us by email or other methods
  • Notes of calls or meetings held or planned
  • Website, device and online activity information, such as IP address, browser type, device identifiers, pages viewed, referring URLs, cookie identifiers, analytics events, pixel tags and similar tracking technologies

Inferred and Derived Information

[Inferred and Derived Information may be categorized as “Inferences” under the CCPA.]
  • Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Audio Visual Information

[Audio Visual Information may be categorized as “Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information” under the CCPA.]
  • Photographs
  • Video images
  • Voicemails

Financial Information

[Financial Information may be categorized as “Commercial Information” under the CCPA]
  • Bank and other financial account numbers and details concerning accounts, including transactions
  • Details concerning accounts, including transactions
  • Nonpublic financial information subject to the Gramm-Leach-Bliley Act

Health Information

[Health Information may be categorized as a “Protected Classifications under California or Federal Law” under the CCPA.]
  • Information about physical or mental health, disability status, medical treatment or diagnosis, or information on payment for health care services that you have provided in relation to client service (e.g., hardship forms, investment planning questionnaires)
  • Information needed to accommodate disabilities

Children’s Information

[Children’s and minors’ information may be categorized as “Protected Classifications under California or Federal Law” or, where applicable, sensitive personal information under the CCPA and Canadian privacy laws.]
  • Information about children listed as beneficiaries of account(s)
  • Information about children or minors provided by you in relation to client service (e.g., included in investment planning questionnaires), subject to any consent or authorization required by applicable law

Compliance Information

[Compliance Information may be categorized as “Personal Information,” “Protected Classifications under California or Federal Law,” “Professional or Employment-Related Information,” or “Commercial Information” under the CCPA.]
  • Compliance program data, including client screening records, individual rights requests, consents, and other records maintained to demonstrate compliance with applicable laws, such as tax laws, know-your-customer or know-your-client requirements, Office of Foreign Assets Control requirements, anti-money laundering requirements, and Foreign Corrupt Practices Act requirements
“Professional or Employment-Related Information,” or “Commercial Information” under the CCPA.]
  • Occupational and environmental safety records
  • Records maintained in conjunction with legal matters or litigation or that are subject to legal holds
  • Records relating to complaints

Purpose for Collecting and Using Personal Information

Depending on how you interact with us, we may use the personal information we collect for one or more of the following business or commercial purposes, and, where required by Canadian law, with your consent or as otherwise permitted or required by law, including:

  • Providing you with information about our products and services;
  • Providing performance and other updates;
  •  One or more of the following business purposes:
    • Performing services (for us or our or your service providers) such as account servicing, processing orders and payments, website operation, personalization, analytics and measurement;
    • Auditing related to our interactions with you;
    • Legal compliance;
    • Detecting and protecting against security incidents, fraud, and illegal activity; o Internal research for technological improvement; o Internal operations;
    • Activities to maintain and improve our services and websites; and
    • Short-term, transient use where permitted by applicable law.
  • Job applications; and
  • Other commercial purposes, including, but not limited to, activities that are undertaken to advance, enable or effect potential commercial transactions, and any other purposes disclosed to you when your personal information is collected or to which you consent.

How Long We Keep Information

How long we keep your personal information will vary primarily depending on the purpose for which we are using your personal information and our legal obligations. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal information). In general, we will retain your personal information for as long as is necessary to provide the relevant services, operate and improve our websites, administer our relationship with you, maintain appropriate business records, resolve disputes, enforce agreements, comply with legal and regulatory obligations, and where laws or regulations set a minimum period for which we are required to keep certain of your personal information. We will securely dispose of, anonymize or deidentify personal information when it is no longer required, subject to legal holds and applicable recordkeeping requirements.

Sensitive Personal Information

Some of the personal information described in the categories listed above also constitutes “sensitive personal information” under the CCPA or may be considered sensitive personal information under Canadian privacy laws, depending on context. We use and disclose sensitive personal information for our business and compliance functions and for other legally authorized purposes, and we seek express consent where required by Canadian law. We do not use or disclose it in a manner that would give rise to a right to limit its use or disclosure under the CCPA.

We may collect sensitive personal information from certain categories of sources, including:

  • Your communications with us and our service providers, including account applications, subscription agreements, and other forms or related documentation;

  • Your and our service providers, including but not limited to: administrators, custodians, brokers, auditors, law firms, accountants, consultants, employment agencies, credit bureaus, other financial institutions;

  • Our affiliates or our affiliates’ service providers;

  • Your employer and your employer’s service providers; and

  • Government entities and other publicly available directories and sources.

We may collect sensitive personal information for the business or commercial purposes described above in “Purpose for Collecting and Using Personal Information”.

With Whom We Disclose Personal Information

Your personal information is intended for Prime Quadrant, including PQUS and PQ Corp., and may be disclosed to Prime Quadrant affiliates, subsidiaries and parent companies and, in certain circumstances, to other parties, including to other parties as directed by you or as otherwise described in this Privacy Notice.

We may disclose your personal information to:

  • External auditors, accountants, and legal and other professional advisors.
  • Our service providers. We use other companies or contractors (service providers) to perform services on our behalf or to assist us with the provision of Prime Quadrant products, services, websites or operations. While we may use a service provider to assist in relation to any of the purposes for which we may collect personal information, they generally fit within one or more of the following categories of service providers:
  • Infrastructure and technology service providers;
  • Fund administrators, counterparties and intermediaries (e.g. broker-dealers) in connection with investments and transactions or for operational purposes;
  • Providers of administrative services for Prime Quadrant products or services, such as transfer agencies, custodians, and securities pricing providers.

In the course of providing such services, these service providers may have access to your personal information. However, we will only provide our service providers with the information that is necessary for them to perform the services, they will act under our instructions, and we instruct them not to use your personal information for any other purpose. We will always use commercially reasonable efforts to ensure that the service providers we work with will keep your personal information secure.

  • Other parties permitted by law. In certain circumstances, we may be required to disclose your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies, or judicial or administrative authorities) or to perform transactions (for example, we may disclose personal information to a custodian or other party in connection with the purchase or sale of securities you have requested). We may also disclose your personal information to other parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, for law enforcement purposes, to enforce our agreements, or to protect your rights or those of the public.
  • Your company or agents and other parties. We may disclose your personal information to your company or other agent, such as when you are included on an email with others or to confirm your details or role. We also may disclose your information to other parties connected with your company or an account or in relation to business transactions we have with you or your company.
  • Other parties connected with business transfers. We may transfer your personal information to other parties in connection with a reorganization, restructuring, merger, acquisition, or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice and applicable law, and subject to any notice or consent requirements under applicable privacy laws.

Security and Location of Personal Information

We have implemented technical and organizational security measures in an effort to safeguard personal information in our custody and control, taking into account the sensitivity of the information. Such measures we have implemented include limiting access to personal information only to employees, contractors, and authorized service providers who need to know such information for the purposes described in this Privacy Notice; training for our employees and contractors; and other technical, administrative, contractual and physical safeguards. Personal information may be processed or stored in the United States, Canada or other jurisdictions where we or our service providers operate. As a result, personal information may be subject to access by courts, law enforcement, regulators or other governmental authorities in those jurisdictions in accordance with applicable law. We use contractual and other measures designed to protect personal information transferred across borders and to provide a comparable level of protection where required by Canadian privacy laws. While we endeavor to always protect our systems, sites, operations, and information against unauthorized access, use, modification, and disclosure, due to the inherent nature of the internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.  

The personal information that we collect may be accessed from or stored in the United States, Canada or other jurisdictions. Due to the nature of our global business and the technologies used, personal information may be accessed from, or transferred to and stored in, other jurisdictions, including jurisdictions that may not provide the same level of privacy protection as your home jurisdiction. Regardless of location, we will put into place appropriate protections and controls to help keep your personal information secure and treated in line with this Privacy Notice and applicable privacy/data protection laws. For Quebec residents, information about our use of service providers outside Quebec may be requested using the contact information below.

Children’s and Minors’ Rights

We do not knowingly collect any personal information directly from children under 16 years of age, and our websites and services are not directed to children or minors. Certain website pages and areas of one or more of our websites may have content that an adult may wish to share with a child. We do not target any advertising to children under 16. The age thresholds and consent requirements that apply to children and minors vary by jurisdiction, and in Canada, including Quebec, consent for the collection, use or disclosure of a minor’s personal information must be provided by a parent or guardian where required by applicable law. If you are a parent or guardian and believe we have collected personal information directly from your child below the applicable age threshold, you may contact us to report this. We will investigate your report, and if we discover that we have in fact collected such information, we will delete it or obtain any consent required by applicable law.

Prime Quadrant Privacy Policy for U.S. Consumer Financial Products and Services

In the course of doing business with Prime Quadrant, including PQUS and PQ Corp., you share personal and financial information with us. We treat this information as confidential and recognize the importance of protecting access to it.

You may provide information when communicating or transacting with us in writing, electronically, or by phone. For instance, information may come from applications, requests for forms or literature, and your transactions and account positions with us. On occasion, such information may come from consumer reporting agencies and those providing services to us.

We do not sell information about current or former customers to any third parties, and we do not disclose it to third parties unless necessary to process a transaction, service an account, or as otherwise permitted by law. We may share information among Prime Quadrant affiliated entities in the course of providing or offering products and services to best meet your investing needs. We may also share that information with companies that perform administrative, marketing, analytics or technology services for Prime Quadrant, with a research firm we have hired, or with a business partner, such as a bank or insurance company, with whom we are offering investment products. When we enter into such a relationship, our contracts restrict the companies’ use of our customer information, prohibiting them from sharing or using it for any purposes other than those for which they were hired.

We maintain physical, electronic, and procedural safeguards to protect your personal information. Within Prime Quadrant, access to such information is limited to those who need it to perform their jobs, such as servicing your accounts, resolving problems, administering websites, or informing you of new products or services. Our Code of Ethics, which applies to all employees, restricts the use of customer information and requires that it be held in strict confidence.

Cookies, Analytics and Online Tracking

Our websites may use cookies, pixels, tags, web beacons, software development kits, analytics tools and similar technologies to operate and secure the websites, remember preferences, understand usage, measure the effectiveness of content and communications, and improve our services. These technologies may collect or infer information such as IP address, device identifiers, browser and operating system information, pages viewed, referring and exit pages, time spent on pages and interactions with emails or online content. We do not knowingly use online tracking technologies to target advertising to children under 16.

Rights of California Consumers

The CCPA provides California consumers with the following rights, subject to certain exceptions and limitations. Residents of other U.S. states may have similar rights under applicable state privacy laws, and we will honor those rights where they apply to us:

  • Be Informed. To be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used;
  • Request to Know. The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we disclosed or sold personal information;
  • Request to Delete. Request that we delete the personal information we have collected from you or maintain about you (subject to certain exceptions);
  • Request to Correct. Request that we correct inaccurate personal information;
  • Opt-Out of Sale. Request that we do not “sell” (as that term is defined in the CCPA) your personal information; (we do not);
  • Opt-Out of Sharing and Certain Targeted Advertising. Request to opt out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties, or of targeted advertising where required by other applicable U.S. state privacy laws (we do not currently sell personal information or share it for cross-context behavioral advertising as those terms are defined by the CCPA);
  • Limit Use and Disclosure of Sensitive Personal Information. Request to limit the use and disclosure of sensitive personal information where required by the CCPA (please note that we are not using your sensitive personal information for purposes that would require that we provide you with such right to request to limit); and
  • Not to Be Discriminated Against. Not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

Shine the Light. For certain categories of personal information, you may have the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties.

How to Submit a Request. You may submit a Request to Know, Request to Correct, Request to Delete or other privacy rights request (“Consumer Rights Request”), as described above or under other applicable U.S. state privacy law to us:

Verifying Requests. We are only required to respond to verifiable Consumer Rights Requests made by you or your legally authorized agent. We will respond to verified requests within the timeframes required by applicable law. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request, which may include, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.

Authorized Agents. You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through one of the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

Canadian Rights Policy

If you are in Canada, you may have rights under the Personal Information Protection and Electronic Documents Act and applicable provincial privacy laws, including Quebec’s Act respecting the protection of personal information in the private sector, as amended by Law 25. Subject to legal limitations, these rights may include the right to request access to personal information we hold about you, request correction of inaccurate or incomplete personal information, withdraw consent to our future collection, use or disclosure of your personal information, request information about our privacy practices and service providers, and make a complaint about our privacy practices. Withdrawing consent may affect our ability to provide requested services or complete transactions, and we may continue to collect, use or disclose personal information where permitted or required by law. Quebec residents may also have rights, where applicable, to request information about computerized processing, profiling, localization or identification functions, and to request deindexation or cessation of dissemination in circumstances provided by law. Requests and complaints should be directed to our privacy contact below. PQ Corp.’s person responsible for the protection of personal information is its Chief Compliance Officer, who may be contacted at the email address below or by mail at PQ Corp., 800-2 St. Clair Avenue East, Toronto, ON M4T 2T5, Canada. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator, including the Commission d’accès à l’information du Québec for Quebec matters.

Changes to this Privacy Policy Notice. We may update this Privacy Notice from time to time to reflect changes in our personal information practices. When we make material changes, we will notify you by posting the updated Privacy Notice on our website with a revised “last updated” date, and where required by applicable law, we will provide additional notice or obtain consent. We encourage you to review the most current Privacy Notice provided to you.

Contact for More Information; Complaints. If you have any questions or concerns about this Privacy Notice, to exercise your privacy rights, to withdraw consent, to submit a complaint, or to request this Privacy Notice in an alternative format, please contact us at:
 

  • Phone: 647-749-4118

  • Mail: Prime Quadrant US, LLC  and Prime Quadrant Corp., 800-2 St. Clair Avenue East, Toronto, ON M4T 2T5, Canada

  • Email: compliance@primequadrant.com
     

This Privacy Notice was last updated on September 9, 2026.