Privacy

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

Our employees, representatives and service providers are committed to protecting your personal information. We maintain internal policies and procedures that define their roles and responsibilities in the management and protection of personal information.

We limit access to and use of your personal information

Access to your personal information is restricted to those who need it to perform their duties. We regularly review and manage access rights based on roles and responsibilities.

We also implement the following safeguards:

• Training for employees, representatives and service providers on proper handling of personal information
• Access and use permitted only with your consent or as allowed by law
• Ongoing monitoring and control of access permissions

We protect our facilities and information systems

We maintain physical, administrative and technical safeguards designed to protect your personal information, including:

• Multi-factor authentication and encryption
• Firewalls and secure network environments
• Authorization controls for systems and facilities
• Continuous monitoring of systems and facilities

We communicate with you securely

We take steps to ensure secure communications when interacting with you, including:

• Verifying your identity before providing account information
• Avoiding the collection of sensitive information unnecessarily over the phone
• Never requesting your password or PIN
• Not contacting you solely to request personal information

We collect your personal information in a variety of ways, including directly from you, from third parties and through our website.

1. Directly from you
   We may collect personal information directly from you, such as when you open an account, deposit money, seek advice about your investments, enter into an investment advisory contract, tell us about your investment or retirement portfolio or earnings, apply for a career opportunity with us or contact us with an inquiry or to report a problem with our website.
2. From third parties
   In certain circumstances, we may receive personal information from third parties, including when you provided your consent for credit verifications, credentials verification and background checks. 
3. Through our website
   We collect technical information (e.g., your IP address, browser type and device ID) and information about your device and browser (e.g. page views and clickstream data) when you visit our website, using technologies, such as cookies. Some of these technologies may be operated by third parties. This information supports the functioning of our website and helps us understand how you navigate and use our website. This information helps to enhance our website’s design and functionality and to optimize our marketing efforts.

iA Private Wealth (USA) uses clients’ personal information for the following purposes:

1. Service Delivery and Business Operations
   To provide, deliver and administer products and services, including processing applications and transactions, maintaining accounts, managing client relationships, responding to inquiries and supporting general business operations (including website functionality and job applications).
2. Identity Verification, Security and Risk Management
   To verify identity, authenticate transactions and protect against fraud, financial crime and threats to information, systems and network security, as well as to support internal risk management, audit and governance activities.
3. Legal and Regulatory Compliance
   To comply with applicable contractual, legal and regulatory requirements, including tax reporting, recordkeeping and other compliance obligations.
4. Client Relationship Management and Support
   To understand client needs and preferences, provide advice, process requests, claims or complaints, and maintain and enhance the ongoing client relationship.
5. Marketing, Personalization and Business Improvement (with consent)
   With consent or as permitted by law, to:
   
   
   • Offer and promote products and services;
   • Better understand client interests and preferences;
   • Improve and develop products, services and the overall client experience; and
   • Optimize marketing efforts.
6. Digital Experience and Website Optimization
   To use technical information (including cookies and similar technologies) to enhance website design and functionality, improve user experience, and support analytics and marketing activities, subject to user privacy choices.

iA Private Wealth (USA) may share clients’ personal information with other individuals or organizations in the following circumstances:

1. With Affiliates, Business Partners and Within the Organization 
   Personal information may be shared within iA Financial Group and with affiliated entities and business partners, to the extent permitted by law, for purposes such as administering products and services, supporting transactions, understanding client experiences and assessing creditworthiness. 
2. Service Providers and Third-Party Vendors
   Personal information may be disclosed to agents, vendors and other third-party service providers who perform services on behalf of iA Private Wealth (USA) (e.g., technology hosting, data processing, analytics, marketing, accounting, legal, compliance or operational support). These providers are contractually required to use the information only for authorized purposes and to maintain appropriate safeguards. 
3. Third Parties Involved in Product and Service Delivery
   Where necessary, personal information may be shared with financial institutions, insurers, reinsurers, brokers, administrators and other organizations involved in delivering or supporting the products and services requested by the client.
4. Legal, Regulatory and Compliance Requirements
   Personal information may be disclosed to regulators, governmental authorities, tax authorities, courts or law enforcement where required or permitted by applicable law, regulation or legal process, or to meet contractual and compliance obligations. 
5. Fraud Prevention, Security and Risk Management
   Information may be shared with credit bureaus, reporting agencies, fraud detection organizations and other third parties to verify identity, assess risk, detect or suppress fraud or illegal activity, protect assets, and support investigations or dispute resolution.
6. Business Transactions and Corporate Changes
   Personal information may be disclosed in connection with a proposed or completed business transaction, such as a merger, acquisition, financing, restructuring, or sale or transfer of all or part of the business, in accordance with applicable law.
7. Other Permitted or Exceptional Circumstances
   In limited situations, iA Private Wealth (USA) may disclose personal information without the client’s knowledge or consent where permitted or required by law, including for investigations, legal proceedings, or to protect the rights, interests, or security of individuals or the organization.

U.S. Federal law gives you the right to limit only:

• Sharing for affiliates’ everyday business purposes—information about your creditworthiness
• Affiliates from using your information to market to you 
• Sharing for non-affiliates to market to you

U.S. State laws and individual companies may give you additional rights to limit sharing.

iA Private Wealth (USA)’s service providers may access, process or store your personal information outside of the jurisdiction where you reside, including in Canada and the United States. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

You have choices about the way iA Private Wealth (USA) handles your personal information.

1. Changing Your Cookie Preferences
   When interacting with online services, clients may manage their cookie and tracking preferences. Only necessary cookies are enabled by default, and clients may choose to enable or disable additional cookies. Limiting certain cookies may affect website functionality.
2. Restricting Collection, Use and Disclosure of Your Personal Information
   You may withdraw your consent to the collection, use and disclosure of personal information in accordance with this notice at any time upon reasonable notice to iA Private Wealth (USA) in writing, subject to legal or contractual restrictions. To withdraw your consent, please contact us in writing using the relevant contact information listed in the Questions? section. The withdrawal of your consent may affect our ability to answer your inquiry. In certain situations, we may be entitled to retain your personal information in order to comply with
   applicable legal requirements, to establish, exercise or defend our rights or legal claims, and for other legitimate business purposes.

You may be entitled to access your personal information and request the rectification of information that is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws. Depending on the jurisdiction where you reside, you may also be entitled to request the rectification of your personal information if our collection, disclosure or retention of such information is not authorized by law. To exercise your rights, please contact us in writing using the relevant contact information listed in the Questions? section.

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including providing products and services, responding to your inquiries and managing our business operations.

Personal information is also retained as required to comply with applicable legal and regulatory obligations, including recordkeeping requirements under Canadian privacy laws and U.S. securities regulations. This may include retaining information after your relationship with us has ended.

When your personal information is no longer required for these purposes, it will be securely destroyed, deleted or anonymized in accordance with applicable laws and our internal retention policies.

Your choices will apply to everyone on your account – unless you tell us otherwise.