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Privacy Policy

Last updated: September 2025

1. Introduction

BlueSky Investment Counsel Inc. ("BlueSky", "we", "us") is committed to protecting personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial and securities regulatory requirements, including the Ontario Securities Commission (OSC) and the Canadian Investment Regulatory Organization (CIRO), as applicable.

2. Personal information we collect

  • Identification: name, address, email, phone, date of birth, and permitted government ID.
  • Financial/KYC: income, net worth, investment objectives, risk tolerance, account details, holdings, transactions, tax residency, employment, source of funds, PEP/sanctions screening results.
  • Website/communications: IP address, device/browser, pages visited, referral sources, marketing preferences, and correspondence.

3. How we use personal information

  • Provide discretionary portfolio management and financial planning.
  • Comply with legal and regulatory obligations (KYC/AML, suitability, tax reporting).
  • Administer accounts, process transactions, and deliver client service.
  • Communicate regarding accounts, service updates, research, and marketing (with consent where required).
  • Maintain security, prevent fraud, and improve services and our website.

4. Lawful basis and consent

We collect, use, and disclose personal information with consent or as otherwise permitted/required by law (e.g., to comply with OSC/CIRO rules, anti‑money laundering laws, and tax reporting). You may withdraw consent for non‑essential uses at any time, subject to legal/contractual restrictions and reasonable notice.

5. Disclosure to third parties

We do not sell personal information. We disclose only as necessary to:

  • Service providers: custodians, brokers, portfolio/account administrators, IT/cloud/security vendors, auditors, legal and tax advisors—subject to confidentiality and security obligations.
  • Regulators/authorities: OSC, CIRO, FINTRAC, CRA, and law enforcement where required by law.
  • Corporate transactions: in connection with financing, merger, or sale, with appropriate safeguards.

6. Cross‑border transfers

Some service providers may operate outside Canada. Personal information processed abroad may be subject to foreign laws. We implement contractual, technical, and organizational safeguards appropriate to the sensitivity of the information.

7. Safeguards

We employ administrative, technical, and physical safeguards designed to protect against loss, theft, unauthorized access, disclosure, copying, use, or modification, including access controls, encryption in transit and at rest where appropriate, secure development practices, employee confidentiality obligations, and vendor due diligence.

8. Retention

We retain personal information as long as necessary for the purposes identified and to comply with legal and regulatory record‑keeping requirements.

9. Your rights

Subject to legal limitations, you may request access to or correction of your personal information. We may need to verify your identity and may be unable to provide information protected by privilege or third‑party privacy rights.

10. Marketing preferences

You may opt‑out of non‑essential marketing communications at any time using the unsubscribe mechanism or by contacting us. Transactional/regulatory communications will continue as required.

11. Cookies, analytics, and ads

We use cookies and similar technologies to operate and improve our site. We use Google Analytics and LinkedIn Insight Tag to understand site usage and ad performance. You can manage cookies via your browser settings and adjust ad preferences within the relevant platforms.

12. Breach response and limitation of liability

We maintain an incident response process designed to detect, contain, investigate, and notify as required by law. While we implement reasonable safeguards, no system is fully secure. To the extent permitted by law, BlueSky is not liable for losses arising from criminal acts, cyber‑attacks, or unauthorized third‑party access beyond our reasonable control, provided we have implemented reasonable safeguards and complied with applicable breach‑notification obligations.

13. Children’s privacy

Our services are intended for adults. We do not knowingly collect personal information from minors without required consents.

14. Updates to this Policy

We may update this Policy periodically. The “Last updated” date will reflect changes. Material changes will be communicated as required.

15. Contact and complaints

Privacy Officer
BlueSky Investment Counsel Inc.
161 Bay Street, Suite 2700, Toronto, ON M5J 2S1
privacy@blueskyic.com | +1‑416‑930‑5550

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or the applicable provincial authority.