Privacy Policy

Last updated: May 20, 2021

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Blue Castle Ventures LTD 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 Blue Castle Ventures LTD collects, uses, discloses and otherwise treats personal information through our website available at www.bluecastleventures.ca, including all subpages and successor pages (collectively referred to as the “Services”) as well as through other interactions with our clients and prospective clients, including our Blue Castle Ventures LTD-branded applications. Blue Castle Ventures LTD Trade has its own privacy policy which can be found here.

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. We strongly encourage you to refer to this Privacy Policy often for the latest information about our personal information practices.

 

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

Blue Castle Ventures LTD needs to collect personal information from our clients and prospective clients in order to provide services to you and fulfill our legal obligations. Understanding a client’s needs and wants, financial position, and personal circumstances enables us to ensure that investment recommendations are suitable and improve our Services. This is both a regulatory requirement and good business. Blue Castle Ventures LTD is committed to protecting our clients’ privacy and the confidentiality of their personal information in our possession. This Privacy Policy explains the measures we take to fulfill these commitments.

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 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 also collect your responses to a risk questionnaire and other regulatory questions that we are required by law to collect.

We limit the use of your personal information.

The personal information we collect when you open an account is used for the following purposes:

  • helping us choose the portfolio that best fits you and your needs;
  • verifying your identity and other information you have provided to us;
  • opening and servicing your account;
  • sending and receiving bill payments through your chequing account;
  • detecting and preventing fraud and other unauthorized or illegal activities;
  • meeting legal and regulatory requirements;
  • tailoring your app experience, including making recommendations for Blue Castle Ventures LTD products or services;
  • improving the Services;
  • 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.

 

Referral Program: 

If you participate in our referral program (or other “Invite a Friend” features that may be available on our Services), we collect the email address of the individual(s) who you wish to refer to Blue Castle Ventures LTD. We use this information to send the recipient a one-time email containing information about the referral program. We do not use the email addresses submitted in these circumstances for any other purpose without the consent of the email recipient to do so. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the email from you.

 

Marketing Communications:

From time to time, we may obtain your consent to send you email, SMS text messages and other communications about Blue Castle Ventures LTD products, services, or events that may be of interest to you. 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 support.

Customer Service/Relationship Manager: 

If you contact a customer service agent or Relationship Manager with a comment, question or complaint by email, text message, 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 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 Blue Castle Ventures LTD, 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.

Gifting: 

If you send a gift (or “Contribute to an Account”), we collect the email address of the individual(s) who you send a gift to, and your payment information. We use this information to send the recipient a one-time email containing the information of your gift. We do not use the email addresses submitted in these circumstances for any other purpose without the consent of the email recipient to do so. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the email from you. We process your payment, and charge your method of payment at the time of purchase. No sensitive payment information data is saved on our servers.

Roundup: 

This program will access your linked accounts(s) on a weekly basis. We will use this information to round your purchase transactions to the nearest dollar and transfer this amount into your Blue Castle Ventures LTD account to be invested. If you change your mind, you can unlink your account(s) at any time.

Overflow: 

Is an automated investing feature that accesses your linked chequing or savings account balance every month and automatically moves any extra cash over the limit you have set (up to a maximum, if you have one) into your Blue Castle Ventures LTD account. We will confirm funds are available and send you a reminder the day of the transfer. If you change your mind, you can skip a transfer or unlink your account at any time. Because the formula is based on cash in excess of the limit you set, by turning on Overflow, you waive the right to receive a pre-notification of the Overflow amount before the debit is processed.

Contacts: 

Sharing your contacts is a feature in Blue Castle Ventures LTD’s Cash app that can allow us to identify which of your contacts in your device’s address book are also using the app. If you choose to share your contacts, you may choose to interact with these contacts, for instance, by sending them money, requesting money, or inviting them to use the app. You may only interact with individuals with whom you have a personal or family relationship and who would want to receive the message from you. We will use these shared contacts to improve our services and offerings, enrich your own app experience, and provide you with better recommendations on potential contacts to invite. We may also share basic contact information (based on your privacy settings) with other users, to confirm they are sending money to the right person, or notifying existing users in your contacts when you join the app.

How we collect personal information.

We collect personal information directly from you, the devices you use to access the Services, and third-party service providers (for example, a credit report as part of identity verification or fraud prevention). When you open a Blue Castle Ventures LTD account, you will be required to open an account with one or more Blue Castle Ventures LTD affiliates. These affiliates may share your information with other Blue Castle Ventures LTD affiliates, including records of transactions and statements of cash and securities in your accounts.

If you decide to fund your account or link a bank account automatically using one of our partners, including Plaid and Flinks, we will receive data collected from your financial accounts, including information from all accounts and sub-accounts (e.g., checking, savings, and credit cards) accessible through the account credentials you used. Your data is stored securely and is encrypted. We may use this data for account verification, funding your accounts, fraud prevention, marketing other Blue Castle Ventures LTD products or services, tailoring your app experience, or improving our Services.

In order to protect you against fraud or from taking actions that may result in non-sufficient funds in your account, we will also collect information related to your bank balance when you fund your account.  This information is also used in our “Roundup Program”.

If you choose to participate in our “Roundup” program, we will collect information related to your account such as your name and address. Additionally, to calculate the eligible round-up amounts to invest in your Blue Castle Ventures LTD portfolio we will collect the types of transactions, vendors, amounts and dates of transactions on a weekly basis.

If you choose to participate in our “Overflow” program, we will collect information related to your account such as your name, address and account balance twice per month. Collecting your account balance will allow us to transfer your requested overflow balance, or determine if no transfer will occur that month. We may also use financial information we collect to identify Blue Castle Ventures LTD products and services, including financial planning services, that you may be interested in or benefit from.

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

In general, you can visit our Services 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 Services and other related information such as page requests, browser type, operating system and average time spent on the Services. We use this information to help us understand activity and to monitor and improve the Services.

Cookies & Similar Technologies: 

The Services use a technology called “cookies”. A cookie is a tiny element of data that the Services 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 Services where you are prompted to log in or that are customizable. If you have registered with the Services, these cookies may let us know who you are and identify your browser as one that has visited the Services 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 Services that we may use to personalize the Services 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 Services, you may not be able to take advantage of all of the features of the Services.

Tracer Tags & Web Beacons: 

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

Analytics: 

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

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 Services 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 limit access to clients’ personal information.

We record clients’ 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 implement safeguards to protect personal information.

Blue Castle Ventures LTD maintains 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 of. 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 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.

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, balance checks, printing, marketing and advertising, hosting, data analysis, legal and accounting.

Business Transactions: 

We may transfer any information we have about you as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Blue Castle Ventures LTD or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Securities Regulations: 

We may share your name, contact information and holdings 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: 

Blue Castle Ventures LTD and its 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 Canadian, US or other law (which may include lawful access requests by Canadian, 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 expect similar safeguards from our service providers.

Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. Your personal information may be maintained and processed by our affiliates and other third-party service providers 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 use online advertising.

We may use third parties such as ad exchanges and data companies to serve our advertisements on our Services or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our 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 Services.

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 Services may contain links to other websites that we do not own or operate. Also, links to our Services 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 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.

We take privacy seriously.

Blue Castle Ventures LTD’s Chief Legal Officer, is responsible for ensuring that Blue Castle Ventures LTD adheres to its privacy policy. The Chief Legal Officer is also 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 us at info@bluecastleventures.ca for any additional clarification desired.

We will provide you with access to your information.

Individuals have the right to access, update, and correct inaccuracies in their personal information that is in Blue Castle Ventures LTD’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, an individual wishing to request access, updating and corrections of inaccuracies in other of his or her personal information in our possession or control may send a request to info@bluecastleventures.ca. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.