Fortüna Risk Management has always been committed to protecting the privacy of its clients' personal information. This notice describes how we collect, keep, use and, where appropriate, disclose your personal information. It is issued under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and equivalent provincial legislation.
The personal information we collect for the purposes described in this notice is kept in a record called your client file. Depending on the service you request, your file may contain additional information; for example, if you set up a pre-authorized payment plan, your financial institution's account number is recorded.
You, or your Fortüna representative, give us information by completing a form, opening an account or giving investment instructions. On our platform this happens at three points, and at each one you decide whether to continue.
You can complete a needs analysis without uploading any document. In that case the figures you state are taken as true and the analysis says so explicitly, because the validity of the recommendation depends on it.
Fortüna Risk Management may collect, keep and use the information in your file, and collect it from or disclose it to third parties, solely for the purposes described in this notice.
The file does not exist only to serve you. It also exists to record what information was on the table when each recommendation was made. That record protects you and protects the advisor equally, and it is why certain records cannot be altered or deleted at will.
The signed needs analysis, the recommendation issued and the date of both are kept unmodified. If you later correct a figure, the correction is recorded alongside the previous value; the original is never overwritten.
You have the right to know who pays for the advice you receive. This practice is supported mainly by commissions paid by insurers when a product is issued through Quality Financial Services, not by what you pay for a session.
A paid session obliges you to buy nothing. If the analysis concludes that you need no product, that is the conclusion and it goes in writing like any other.
The law requires Fortüna Risk Management to use your social insurance number for the tax reporting required by the Canada Revenue Agency. It may also be provided to third parties engaged to prepare tax reports. It is used for no other purpose, and it is not requested before payment of an event.
Your personal information is not shared with the sales representatives of any other company without your consent. When we transfer information to a service provider, we require by contract that it be used only for the purpose for which the provider was engaged.
You may withdraw your consent to this communication of information, or ask about the consequences of withdrawing it, by writing to the address below. In some circumstances the law prevents withdrawal. Withdrawing it may limit the products and services we can offer you, because collection and disclosure to certain third parties are a necessary part of making them possible.
Files, electronic or paper, are kept at the offices of Fortüna Risk Management and of your representative. Paper records may also be held in secure on-site storage, and the file may be replicated in other locations for disaster recovery.
All information travels encrypted in transit and stays encrypted at rest. No card data passes through our systems: payments are processed by Stripe and we receive only the transaction confirmation.
We work with providers who supply technical services to us: storage of your documents (Google Workspace, under Fortüna's corporate account), email delivery and payment processing. Some of those providers may process or store information outside Canada. Canadian law (PIPEDA) allows this as long as the information remains protected to a degree comparable to what is required here, and that is what we agree by contract with each of them. While information is held by a provider, it is also subject to the law of the country where it is located.
We use artificial intelligence to read documents and prepare drafts, and it works under conditions we set and that it cannot bypass. The tool is not the problem; your information is what deserves a fence, and Fortüna is the one who puts it up. Before any text leaves our systems, your name, social insurance number, address, phone and email are stripped out: what reaches the other side are figures and dates, never someone identifiable. If that replacement cannot be verified, the document does not leave and a person handles it. We also require the provider not to keep or reuse what it receives. And no machine draft reaches you as it came: a licensed advisor reviews it, corrects it and answers for it. The machine proposes; the person answers.
Fortüna employees and representatives may access your file only if they have a specific need to know it for the purposes of this notice, and only to the extent necessary for that purpose.
All administrative access is logged with user, date and reason. You can request the access log for your own file by writing to the privacy officer.
When the advisory relationship is formalized, you receive access to your own portal. What you edit updates your file; what your advisor records stays visible but not editable, because it is part of the professional record that regulation requires be kept intact.
You can request deletion of your information at any time and we address the request within thirty days. If there is an active policy placed through us, insurance regulation requires us to keep the associated file; in that case we tell you exactly what is deleted, what must remain and why.
Canada's anti-spam law (CASL) requires that you know who is writing to you, why, and how to stop receiving it. Our emails go out identified as Jaime Olarte, with the office's postal address and an unsubscribe link in the footer.
The authorization box is never pre-checked. If you do not check it, payment does not proceed and we do not write to you. Checking it authorizes communications about the service you contracted; the commercial and newsletter categories are authorized separately and are withdrawn without affecting the others.
Except in the limited circumstances provided by PIPEDA and equivalent provincial legislation, you have the right to access, by written request, the personal information in your file, verify it and ask that any inaccurate data be corrected. We also ask you to promptly inform us of any change in the information you have already provided.
Any question, request for access, correction or deletion goes to the privacy officer, at info@jaimeolartefinanzas.com. We respond within thirty days. If your concern is not resolved to your satisfaction, you may escalate it to Fortüna's head office and, ultimately, file a complaint with the Office of the Privacy Commissioner of Canada.
When something material changes we update the date in the header and notify by email those with an active file before the change takes effect. Prior versions remain available on request. Fortüna Risk Management's corporate policy can be consulted at fortunariskmanagement.com, and information about PIPEDA on the site of the Privacy Commissioner of Canada.