Privacy policy

1. Introduction

David Cooke Wealth Counsellors Inc. (“DCWC”) ("we," "our," or "us") is committed to protecting the privacy of our clients, prospective clients, and website visitors. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in the course of providing wealth management and financial advisory services, and in operating our website at www.dcwealth.ca.

This policy is intended to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL), as well as any applicable provincial privacy legislation. By engaging our services or using our website, you acknowledge that you have read and understood this Privacy Policy.

2. Who we are

DCWC is a wealth management and financial advisory firm operating in Canada. We assist individuals, families, and businesses in achieving their financial goals through personalized investment planning, portfolio management, retirement planning, estate planning, and related advisory services.

DCWC acts as the "organization" responsible for personal information under its control, as defined under PIPEDA. Questions or concerns regarding this Privacy Policy may be directed to our Privacy Officer (see Section 13).

3. Information we collect

We collect personal information only to the extent necessary to provide our services and as permitted by law. The types of information we may collect include:

3.1 Information you provide directly

Full legal name, date of birth, and government-issued identification details
Contact information, including mailing address, telephone number, and email address
Financial information, including income, assets, liabilities, investment objectives, risk tolerance, and net worth
Tax identification information (Social Insurance Number) as required for regulatory compliance
Employment information and business interests
Beneficiary and dependent information relevant to financial planning
Communications you send to us, including through our website contact forms, by email, or by telephone

3.2 Information collected automatically

When you visit www.dcwealth.ca, we may automatically collect certain technical information, including:

IP address and general geographic location
Browser type and version, and operating system
Pages visited, time spent on pages, and referring URLs
Cookie identifiers and similar tracking data (see Section 10)

3.3 Information from third parties

We may receive personal information about you from third parties where permitted by law, including from:

Custodians, depositories, and financial institutions
Credit reporting agencies
Regulatory bodies (e.g., FINTRAC, securities regulators), where required by law
Referral sources, with your consent

4. How we use your information

DCWC collects and uses personal information for the following purposes, in accordance with the principle of limiting use to the purposes identified at or before the time of collection:

Establishing your identity and completing Know Your Client (KYC) requirements as mandated by applicable securities and anti-money laundering legislation
Providing personalized financial planning, investment advisory, and portfolio management services
Processing transactions and maintaining accurate account records
Communicating with you regarding your accounts, market updates, and changes to our services
Sending you commercial electronic messages where you have provided express or implied consent under CASL (see Section 9)
Complying with applicable legal and regulatory obligations, including obligations under PIPEDA, the Income Tax Act, FINTRAC requirements, and provincial securities legislation
Investigating and resolving complaints or disputes
Improving our services and website functionality through analytics
Preventing and detecting fraud and other illegal activities

5. Legal basis for collection and consent

Under PIPEDA, DCWC relies on the following legal bases for collecting, using, and disclosing your personal information:

You have actively provided consent, such as by signing a client engagement agreement or checking an opt-in box.

Express consent:

Consent is implied from the context — for example, when you provide your contact details to receive a service quote. Implied Consent:
Collection or disclosure is required or authorized by law (e.g., anti-money laundering reporting obligations).

Legal requirement:

Collection is necessary for a legitimate purpose, and a reasonable person would expect such collection in the circumstances.

Legitimate business purpose:

You may withdraw your consent at any time for purposes that are not legally required, subject to reasonable notice. Withdrawal of consent may limit our ability to provide certain services.

6. Disclosure of your information

DCWC does not sell, rent, or trade your personal information. We may disclose your information only in the following limited circumstances:

We engage trusted third-party service providers (e.g., custodians, technology vendors, compliance consultants, professional advisors) who process information on our behalf under contractual privacy obligations consistent with PIPEDA.

Service providers:

We may disclose information to government authorities, securities regulators, FINTRAC, tax authorities, or as otherwise required by law or court order.

Regulatory and legal obligations:

In the event of a merger, acquisition, or sale of our business, personal information may be transferred to the successor entity, subject to equivalent privacy protections.

Business transactions:

We may share your information with other parties where you have given explicit consent.

With your consent:

Where service providers are located outside of Canada, your information may be subject to the laws of the jurisdiction in which they are located. We take contractual steps to protect your information when transferred internationally.

7. Retention of personal information

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. In general:

Client account records are retained for a minimum of seven (7) years following the termination of the client relationship, in accordance with securities regulatory requirements.
Website visitor data (e.g., server logs) is typically retained for up to 12 months.
Marketing communication records are retained as necessary to demonstrate CASL compliance.

When personal information is no longer required, we securely destroy, delete, or de-identify it using methods appropriate to its sensitivity.

8. Your privacy rights

Under PIPEDA, you have the following rights regarding your personal information held by DCWC:

You may request access to the personal information we hold about you, and information about how it has been used and disclosed.

Right of access:

If you believe personal information we hold is inaccurate, incomplete, or outdated, you may request that it be corrected or amended.

Right to correction:

Subject to legal and contractual restrictions, you may withdraw consent to our use of your information at any time.

Right to withdraw consent:

You have the right to lodge a complaint with our Privacy Officer, or with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.

Right to Complain:

To exercise any of these rights, please submit a written request to our Privacy Officer (see Section 13). We will respond within 30 days. In certain circumstances, we may be unable to fulfill a request (e.g., where disclosure would reveal information about another individual, or where prohibited by law), and we will explain the reason for any refusal.

9. Electronic communications and CASL

Canada's Anti-Spam Legislation (CASL) governs commercial electronic messages (CEMs) sent to electronic addresses. DCWC complies with CASL as follows:

We will only send marketing CEMs to individuals who have expressly opted in to receive such communications.

Express consent:

We may send CEMs to existing clients or individuals with whom we have an existing business relationship, for a period not exceeding two (2) years following our last transaction or interaction, unless express consent has been obtained or consent is withdrawn.

Implied consent:

All CEMs will clearly identify DCWC as the sender, include our contact information, and contain an unsubscribe mechanism.

Identification:

You may unsubscribe from marketing communications at any time by clicking the 'unsubscribe' link in any email we send, or by contacting our Privacy Officer. We will process unsubscribe requests within 10 business days.

Unsubscribe:

Transactional and relationship communications — such as account statements, regulatory notices, service updates, and responses to your enquiries — are not subject to CASL consent requirements and will continue regardless of your marketing preferences.

10. Cookies and online tracking

Our website uses cookies and similar tracking technologies to enhance your browsing experience and gather analytics. Cookies are small text files stored on your device.

Required for the website to function properly. These cannot be disabled.

Essential Cookies:

Help us understand how visitors use our website (e.g., Google Analytics). These may be disabled without affecting core functionality.

Analytics Cookies:

Used to deliver relevant content. We obtain consent before setting non-essential cookies.

Marketing Cookies:

You may control or delete cookies through your browser settings. For more information about managing cookies, visit www.allaboutcookies.org. Note that disabling certain cookies may affect website functionality.

11. Security of personal information

DCWC employs physical, administrative, and technical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. Our security measures include, but are not limited to:

Encrypted transmission of data using SSL/TLS protocols
Access controls and authentication requirements for staff accessing client information
Regular staff training on privacy and data security obligations
Secure document handling and destruction policies
Data breach response procedures in accordance with PIPEDA's mandatory breach reporting requirements

In the event of a privacy breach that poses a real risk of significant harm, we will notify the Office of the Privacy Commissioner of Canada and affected individuals as required by law, and take prompt steps to contain and remediate the breach.

12. Third-party websites

Our website may contain links to third-party websites, including financial news sources, custodian portals, and regulatory bodies. DCWC is not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party website you visit.

13. How to file a complaint

If you wish to register a privacy concern with DCWC you may contact the company directly via its Principal, David Cooke.

You may file a complaint with the Office of the Privacy Commissioner of Canada at:

Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376 | www.priv.gc.ca

14. Changes to this Privacy Policy

DCWC may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. Material changes will be posted on our website at www.dcwealth.ca with an updated "Last Revised" date. We encourage you to review this policy periodically. Continued use of our services following notice of a material change constitutes acceptance of the revised policy.