Doing business with Viewpoint Investment Partners Corp. (“Viewpoint,” “we,” “us,” or “our”) involves sharing personal information with us. This policy explains how we collect, use, disclose, and protect that information across all of our services — including our website (viewpointgroup.ca) and the Viewpoint Private Wealth mobile application (the “App”).
We are committed to protecting your privacy in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Law 25), and all other applicable Canadian privacy legislation.
1. Accountability
Viewpoint Investment Partners Corp. is responsible for the personal information under its control.
Privacy Officer:
Paula Sexsmith
Viewpoint Investment Partners Corp.
Email: info@viewpointgroup.ca
Phone: 1-844-393-8465
Our Privacy Officer oversees compliance with this policy and applicable privacy legislation. All staff who access personal information are bound by confidentiality obligations and receive training on their privacy responsibilities.
2. Scope
This policy applies to personal information collected:
- Through our website at viewpointgroup.ca
- Through the Viewpoint Private Wealth mobile application (iOS and Android)
- Through direct communications with us (email, telephone, written correspondence)
- Through our client onboarding and account management processes
3. What Personal Information We Collect
Website visitors:
- Contact information submitted through our website (name, email address, dealer/rep code)
- Technical information collected automatically via cookies and analytics tools (IP address, browser type, pages visited, time of visit)
Mobile App users:
- Authentication credentials — your email address, used to verify your identity through our secure authentication provider (Auth0 by Okta). We do not store your password on your device or our servers.
- Financial account data — portfolio information, investment returns, holdings, transactions, and investor documents, retrieved on demand from our servers. This data is not permanently stored on your device.
- Notification preferences and device token, stored only if you enable push notifications.
- Feedback content — the text of messages you submit, along with your identity.
- Anonymous usage analytics — screens visited and actions taken, associated with your client identifier. This data does not include financial information or personally identifiable information beyond your client identifier.
The App does not collect your device’s location, contacts, camera, microphone, photos, or browsing history. The App does not use advertising identifiers or tracking technologies and does not serve advertisements.
Clients of Viewpoint Investment Partners:
In the course of providing investment management services, we collect personal information required by applicable law and regulation, including:
- Full legal name, date of birth, and government-issued identification
- Contact information (address, phone number, email address)
- Financial information (income, net worth, investment objectives, risk tolerance)
- Social Insurance Number, for tax reporting purposes
- Banking information, for account settlement purposes
- Records of transactions and correspondence
4. Identifying Purposes
We collect and use personal information for the following purposes, identified at or before the time of
collection:
- To verify your identity and establish or maintain your account
- To protect against error, fraud, and unauthorized access
- To provide investment management and portfolio reporting services
- To comply with applicable legal and regulatory requirements, including know-your-client, anti-money laundering, and tax reporting obligations
- To communicate with you about your account, including statements, reports, and investment commentary
- To deliver optional push notifications about new investment commentary published by Viewpoint
- To receive and respond to feedback submitted through the App
- To analyze anonymous usage patterns to improve the functionality and reliability of our website and App
If we identify a new purpose for your personal information, we will notify you and obtain your consent before using it for that purpose, unless the new use is required by law.
5. Consent
We obtain your express or implied consent before collecting, using, or disclosing your personal information.
Express consent is required for sensitive personal information, including financial data and government identification.
Implied consent applies where the purpose of collection is obvious and you voluntarily provide the information — for example, when you submit a contact form on our website.
Mobile App:
By creating an account and using the App, you consent to the collection, use, and disclosure of your personal information as described in this policy. Specific consents include:
- Financial data: Your use of the App constitutes implied consent to retrieve and display your portfolio information from Viewpoint’s servers.
- Push notifications: Notification permissions are requested separately through your device’s operating system. You may enable or disable notifications at any time through the App or your device settings.
- Analytics: Anonymous usage analytics are collected to improve the App and do not include financial data or personally identifiable information beyond your client identifier.
- Feedback: Submitting feedback constitutes consent to collect and store your message and identity for the purpose of responding to your inquiry.
Withdrawing consent: You may withdraw your consent at any time, subject to legal or contractual restrictions, by contacting our Privacy Officer. Withdrawal of consent may affect our ability to provide certain services.
Exceptions: We may collect, use, or disclose personal information without your consent where permitted or required by law — for example, to comply with a court order, regulatory requirement, or where obtaining consent would be impracticable.
6. Limiting Collection
We collect only the personal information necessary for the purposes identified in this policy. We do not collect information indiscriminately.
7. Use, Disclosure, and Retention
Use: We use your personal information only for the purposes for which it was collected, or as otherwise permitted by law.
Disclosure: We do not sell, rent, or share your personal information with third parties for marketing or advertising purposes. We may disclose personal information to:
- Regulatory and legal authorities, where required by law (e.g., securities regulators, tax authorities, law enforcement)
- Third-party service providers who process data solely for the purposes of operating our services. These providers are contractually obligated to protect your information and may not use it for any other purpose:
If we engage additional service providers who process personal information on our behalf, we will update this policy accordingly.
Retention:
- Active client accounts: Personal information is maintained for the duration of your client relationship.
- Post-termination: Upon termination of your client relationship, personal information is retained only as required by applicable securities regulations — generally a minimum of seven years — and then securely destroyed.
- App analytics data: Retained in aggregate, anonymized form after 12 months and is no longer linked to identifiable individuals.
- Locally stored App data: If you uninstall the App, all locally stored data — including authentication tokens and notification preferences — is automatically removed from your device.
- Website contact inquiries: Retained for as long as necessary to respond to your inquiry and for a reasonable period thereafter.
8. Accuracy
We take reasonable steps to ensure that the personal information we hold is accurate, complete, and up to date for the purposes for which it is used.
Financial data displayed in the App is sourced directly from Viewpoint’s portfolio management systems and is updated each time you access the App.
If you believe any personal information we hold about you is inaccurate or incomplete, please contact our Privacy Officer and we will correct it promptly.
9. Safeguards
We protect your personal information using security measures appropriate to the sensitivity of the information
Website and server-side:
- Data is stored behind a firewall on our network and protected by operating system authentication, database security, and individual user access controls.
Mobile App:
- In transit: All data is transmitted over encrypted connections using TLS/HTTPS.
- On device: Authentication tokens are stored using platform-native secure storage (iOS Keychain / Android Keystore), providing hardware-backed encryption.
- At rest: Financial data is not cached or stored permanently on your device. Server-side data is protected by the measures described above.
- Access controls: Access to client data is restricted to authorized Viewpoint personnel on a need-to-know basis.
Breach notification: In the event of a breach of security safeguards that creates a real risk of significant harm to you, we will notify you as soon as reasonably possible and report to the applicable privacy regulator(s) as required by law.
10. Cookies
Our website uses cookies — small data files placed on your device — to measure activity, remember your preferences, and improve your experience.
We request your consent before placing non-essential cookies. You can manage your cookie preferences at any time using the cookie settings available on our website. You may also configure your browser to refuse cookies or to alert you when cookies are being sent; however, some parts of our website may not function properly if you do so.
We do not use cookies to collect personally identifiable financial information.
11. Openness
This policy is written in plain language and describes our privacy practices in full. You may request additional information about how we manage personal information at any time by contacting our Privacy Officer.
This policy is available on our website at viewpointgroup.ca/privacy-policy/ and within the Viewpoint Private Wealth App.
12. Individual Rights
Upon written request to our Privacy Officer, you have the following rights:
Access: The right to be informed of the existence, use, and disclosure of your personal information held by Viewpoint, and to receive a copy of that information, subject to limited exceptions permitted by law (for example, information that would reveal personal information about another individual, or information subject to solicitor-client privilege).
Correction: The right to request correction of any inaccuracies in your personal information.
Erasure: In certain circumstances — for example, where your personal information is no longer necessary for the purposes for which it was collected and retention is not required by law — the right to request that your personal information be deleted.
Data portability: The right to receive your personal information in a structured, commonly used format, or to have it transmitted to another organization on your request, where technically feasible.
We will respond to all requests within 30 days. If we cannot fulfill a request — in whole or in part — we will explain the reasons and inform you of any recourse available to you.
13. Challenging Compliance
If you have a concern about our privacy practices or believe we are not complying with this policy or applicable privacy law, you may:
- Contact our Privacy Officer at info@viewpointgroup.ca or 1-844-393-8465. We will investigate all complaints and respond within 30 days.
- File a complaint with the Office of the Privacy Commissioner of Canada (OPC): www.priv.gc.ca | 1-800-282-1376
- If you are a Quebec resident, file a complaint with the Commission d’accès à l’information
(CAI): www.cai.gouv.qc.ca | 1-888-528-7741
14. Children’s Privacy
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children.
15. Changes to This Policy
We may update this policy from time to time. Material changes will be communicated through the App, by email to registered users, or by posting a notice on our website. Continued use of our services following any changes constitutes your acceptance of the updated policy.
Viewpoint Investment Partners Corp. reserves the right to change this policy at any time.
Last updated: April 2026