Privacy Policy

Last Updated: March 6, 2022

What this policy covers 

Your privacy and trust are important to Shellman Invest, and so is being clear about how we collect, use, and disclose information about you. This policy is intended to help you understand: 

  • The type of personal information we collect 

  • How we use the personal information we collect 

  • Other personal information we collect and use 

  • How we restrict the disclosure of your personal information 

  • Safeguarding your personal information 

  • Contacting Shellman Invest Privacy 

  • Accessing your personal information 

  • How we collect your personal information online, through our website and app, online advertising and third party links 

  • Our Affiliates 

“Shellman Invest”, “we”, “us” or “our” means collectively Shellman Invest and its affiliates that offer investment services (collectively referred to as “Affiliates” and listed below) is committed to protecting the privacy and confidentiality of personal information in our possession and control. This Privacy Policy explains the measures we take to fulfill these commitments and describes the manner in which we collect, use, disclose and otherwise treat your personal information through our mobile app (the “App”) and website, including all subpages and successor pages (collectively referred to as the “Website”) as well as through other interactions with our clients and prospective clients, including our Shellman Invest-branded applications. 

This Privacy Policy will continue to apply for as long as we hold your information, including after the termination of any of your product or service with us. By providing us with your personal information, you are consenting to the collection, use and sharing of your personal information as set out in this Privacy Policy. 

This Privacy Policy may be updated periodically to reflect changes to our privacy practices. Any changes we make to this Privacy Policy will be effective when we post the revised policy on our Website. We strongly encourage you to refer to this Privacy Policy often for the latest information about our privacy practices. By continuing to interact with us after the modified version of the policy has been posted, you are accepting the changes to the policy. 

We ask our clients for no more personal information than necessary. 

We collect personal information from our clients and prospective clients for purposes that include the following: 

  • complying with legal obligations and industry regulations; 

  • to better understand our clients’ financial position, needs and wants and personal circumstances so that we can provide advice, recommendations or account and product assessments (where applicable); and 

  • to understand how our clients use our Websites, to help improve our products and services. 

The “Know Your Client” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements, including: name, address, phone and fax numbers, email addresses, birth date, social insurance numbers (for tax reporting purposes), asset holdings and values, investment knowledge and objectives. We also collect your chequing account information, transactional history, account balances/limits and optional beneficiary information (e.g. spouse’s name and occupation, children’s and dependents’ names and ages). 

Our application forms for registered retirement accounts elicit only the information needed to register these accounts with the government including: social insurance number, spouse’s or designated beneficiary’s name and birth date. We also collect your responses to a risk questionnaire and other regulatory questions that we are required by law to collect. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this Privacy Policy. 

We continually monitor our data collection practices and encourage you to reach out to us if you have any questions or concerns about these practices. 

We limit the use of your personal information. 

In addition to the purposes identified to you before or at the time of collection, the personal information we collect when you open an account is used for the following purposes, as applicable: 

  • understanding your financial needs and delivering financial products and services that help meet them; 

  • helping us choose the portfolio that best fits you and your needs; 

  • verifying your identity and other information you have provided to us; 

  • manage your relationship among Shellman Invest services and Affiliates , including opening and servicing your account and maintaining accurate and consistent information about you; 

  • help manage and assess our risks and operations; 

  • detecting, preventing and suppressing errors, fraud, financial abuse and other unauthorized or illegal activities; 

  • meeting legal and regulatory requirements, including self-regulatory organizations; 

  • tailoring your app experience, including making recommendations for Shellman Invest products or services; 

  • de-identifying your information by removing personal identifiers such as your name, address and account numbers. This information may be aggregated and anonymized so that it cannot be used to identify individuals, and then used for analytics and reporting, developing and improving our products and services, and identifying trends and insights that may be of value to us and our clients; 

  • transferring your account to or from another institution; and 

  • as otherwise required or permitted by applicable law. 

Other ways we collect and use personal information. 

Marketing Communications: From time to time, we may send you email, SMS text messages and other communications about Shellman Invest services, or events that may be of interest to you, as well as products, services or events of our Affiliates. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained in each of our email communications. Please note that you will continue to receive email regarding your account and transactions with us. Alternatively, you can unsubscribe from any of our marketing communications by contacting us at info@Shellmaninvest.com. 

Customer Service/Relationship Manager: If you contact a customer service agent or Relationship Manager with a comment, question or complaint by email, text message, web chat, telephone or video chat, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may record the conversation or retain this information to assist you in the future and to improve our customer service and, product and service offerings. 

Employment: If you inquire about or apply for a job with Shellman Invest or any of its Affiliates, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities. 

How we collect personal information. 

We collect personal information directly from you, the devices you use to access the Websites, and third party service providers (for example, from credit reporting agencies as part of identity verification or fraud prevention).  

Your data is stored securely and is encrypted. We may use this data for account verification, funding your accounts, fraud prevention, marketing other Shellman Invest products or services, tailoring your app experience, or improving and developing our Website, products and services. 

We restrict disclosure of personal information. 

We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out in this Privacy Policy. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this Privacy Policy. 

Service Providers: We may transfer your personal information to our Affiliates and other third party service providers who provide various services on our behalf such as identity verification, technology, administration, printing, marketing and advertising, hosting, data analysis, legal and accounting. We restrict service providers’ access to clients’ personal information only on a “need to know” basis in order to fulfill their requirements. 

Securities Regulations: We may share your personal information, including name, contact information, holdings and beneficiary information with issuers of securities that you hold in your account and other persons/companies as required in accordance with securities law. Such issuers may require your personal information in order to deliver financial reports, tax documents and other relevant materials to you or to comply with applicable regulatory obligations. We may also disclose certain personal information, including the number of and purchase price of units purchased, to the applicable Canadian securities regulatory authority where required by law. 

Legal: We and our Uruguayan Affiliate and third party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable US or other law (which may include lawful access requests by, US or other foreign courts, law enforcement or governmental authorities). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property. 

We implement safeguards to protect personal information. 

We maintain reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification and disclosure. We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign our privacy document that obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information. 

Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). 

We have personal information retention processes designed to retain personal information of our clients and prospective clients for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal requirements. 

 

We limit access to clients’ personal information. 

We store personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees and service providers to have access to clients’ personal information only on a “need to know” basis in order to fulfill their job requirements. 

We require similar safeguards from our service providers. 

Our service providers are transferred the information they need to perform their designated functions and committed to maintaining your confidentiality. Our service providers are not permitted to use your information for any unauthorized purpose. Your personal information may be maintained and processed by our Affiliates and other third party service providers outside of in the US or other jurisdictions. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions. 

We take privacy seriously. 

Shellman Invest's Chief Compliance is responsible for ensuring that Shellman Invest adheres to its privacy policy. The Chief Compliance Officer is responsible for training our employees in our privacy policies and for monitoring the fulfillment of our privacy commitments. We invite any client or prospective client to contact our Chief Compliance Officer at the contact information set out below for any additional clarification desired. If you wish to review your personal information in our possession, please send a written request to this effect to compliance@shellmaninvest.com 

We will provide you with access to your information. 

Individuals have the right to access, update, and correct personal information in Shellman Invest’s custody and control, subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account and clicking “Settings”. Otherwise, if you wish to request access, updating and corrections of inaccuracies in personal information in our possession or control, you may send a written request to this effect to compliance@shellmaninvest.com. 

We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. 

We collect and use information about your visit to our website or use our apps. 

In general, you can visit our Websites without indicating who you are or submitting any personal information. However, we collect and/or maintain the IP (Internet protocol) addresses of all visitors to the Websites and other related information such as page requests, browser type, operating system and average time spent on the Websites. We use this information to help us understand activity and to monitor and improve the Websites. 

Cookies & Similar Technologies: The Websites use a technology called “cookies”. A cookie is a tiny element of data that the Websites can send to your browser, which may then be stored on your hard drive so that you can be recognized when you return. We use cookies on the pages on the Websites where you are prompted to log in or that are customizable. If you have registered with the Websites, these cookies may let us know who you are and identify your browser as one that has visited the Websites before and may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services. We also use cookies to provide us and our service providers with information about your use of the Websites that we may use to personalize the Websites or other content in accordance with your interests and preferences (e.g. language preference) and improve your user experience. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Websites, you may not be able to take advantage of all of the features of the Websites. 

Tracer Tags & Web Beacons: The Websites may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on the Websites. These tracer tags are used to help us optimize and tailor the Websites for you and other future visitors to the Websites. 

Analytics: We may use third parties, including Google Analytics, to help us gather and analyze information about the areas visited on the Websites in order to better understand, evaluate and improve the user experience and the convenience of the Websites. 

Social Media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on the Websites or our applications and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request. 

We use online advertising. 

We may use third parties such as ad exchanges and data companies to serve our advertisements in the App, on our Websites or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our App, the Websites and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Websites. To learn more about this behavioural advertising practice or to opt-out of this type of advertising, you can visit the Digital Advertising Alliance website at  www.aboutads.info/choices/ or the Digital Advertising Alliance of Canada website at  www.youradchoices.ca/choices. 

We may provide links to third party websites. 

Our Websites and App may contain links to other websites that we do not own or operate. Also, links to our App or Websites may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility, accountability or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.