Privacy Policy

To fulfill our regulatory obligations and ensure a thorough understanding of your needs, we must collect certain personal information. Aware of its importance, we are fully committed to the protection of such information. All client information acquired is treated confidentially, regardless of its nature. Any information that is no longer required for the purposes for which it was initially obtained is securely destroyed, deleted, or anonymized.

Sterna Asset Management Inc. (“STERNA”) must collect the necessary information to properly know its client, confirm their identity, ensure the suitability of the products we recommend, prevent and detect fraud, abuse, unauthorized or illegal activities, and comply with obligations related to anti-money laundering and anti-terrorist financing regulations.

As such, STERNA collects personal data, including but not limited to: name, date of birth, marital status, email address, copies of identification documents, signature samples, and certain financial and account-related information, such as salary, debts, and other financial assets, as part of the “Know Your Client” (KYC) process.

We collect personal information directly from you when you communicate or interact with us. In some cases, we may also obtain information indirectly from various sources. When required, we obtain your consent. These sources may include:

• Publicly available records and information sources
• Regulatory and self-regulatory organizations
• Data derived from your use of our website
• Brokers and other participants in the securities industry
• Credit reporting and assessment agencies (if applicable)

Sharing Your Information

In certain situations, it may be necessary to share your personal information with third parties, whether for legal compliance, fraud prevention, or service provision on our behalf. We always ensure that information sharing is limited to what is strictly necessary and obtain your consent where required. Under no circumstances do we sell client lists to third parties.

STERNA may share your information with:

• Internal employees for compliance purposes and the day-to-day management of your accounts
• A person or representative acting on your behalf or at your request
• Another financial institution or a credit assessment agency
• A clearing or settlement system
• A co-account holder or another party involved in your relationship with us
• Third parties in the context of legal proceedings
• Regulatory or government authorities, or self-regulatory organizations
• Any legally authorized entity
• Third parties involved in a business transaction
• Service providers performing tasks such as investment statement production, data hosting, storage, and backup services

The Personal Information Protection and Electronic Documents Act (PIPEDA) requires clients to consent to the collection and sharing of personal information with certain third parties or regulatory and legal authorities. However, consent is only valid if it is reasonable to expect that the individual understands the nature, purposes, and consequences of collecting, using, or disclosing their personal information.

STERNA respects an individual’s decision to refuse to share certain requested personal information. However, STERNA will decline to provide services to any client who does not consent to the collection and use of personal information as described above, as such data is essential for fulfilling our obligations and delivering our services.

Withdrawing Consent

You may refuse the use of your personal information or withdraw your consent for the following purposes:

• Receiving promotional offers, newsletters, etc.
• Collecting and using your digital information from our online services
• However, you will continue to receive:
• Regulatory notices that we are legally required to send
• Service messages related to account statements, if applicable
• Information concerning your existing products and services

STERNA must provide access to personal information upon a client’s request. When a current or former client requests access, STERNA must confirm whether it holds personal information about them and provide access as soon as possible, but no later than 30 days from the request.

We retain collected information in physical or digital formats. Physical records are securely locked, while digital records may be stored securely outside of Québec and Canada, as STERNA and its service providers or third-party partners may operate in other jurisdictions. Retention periods are determined based on purpose, data sensitivity, and legal or regulatory requirements. Information related to client profiles (name, address, date of birth, etc.) and all subsequent updates are kept for the duration of the relationship, plus an additional seven years after termination.

Certain exceptions may require extended retention, such as disputes or claims, in which case information may be retained longer. Once the retention period expires, data is securely destroyed.

This policy may be updated as necessary. A notice will be published on our website when changes occur.

Our Chief Privacy and Data Protection Officer is responsible for ensuring compliance with these practices at STERNA. For any questions regarding this policy, you can contact them at: conformite@sternafinance.ca.