Last Revised: September 12, 2024
Altrust Investment Solutions Inc. (“Altrust”) is a registered exempt market dealer (“EMD”), whose primary regulator is the Ontario Securities Commission. Altrust owns and controls this website and makes available the products and services accessible herein acting under the business name Midasboard (“Midasboard”, “we”, “our” or “us”) and/or its affiliates. Midasboard offers a technology-enabled EMD service (the “Platform”) to facilitate the purchase of select private securities by investors.
Your privacy and trust are important to Altrust and Midasboard, and so is being clear about how we collect, use, and disclose information about you. This privacy policy (“Privacy Policy”) also covers our treatment of any personal information that our business partners share with us or that we share with our business partners. For the purposes of this Privacy Policy, “you”, “your” and “user” means you as a user of the Site (as defined below) or the Platform.
Please read this Privacy Policy carefully. When you use the Site or the Platform, you are consenting to the collection, use, and disclosure of your personal information described in this Privacy Policy and in accordance with applicable law (see Consent for further details). If you do not agree to this Privacy Policy, please do not use or access the Site or Platform.
You do not have to register to visit the Midasboard website. However, if you choose to create an account in order to participate in the Midasboard Platform (“Account”), we will require certain information from you, and this Privacy Policy is incorporated into the applicable terms and conditions that govern your relationship with Midasboard. By accessing this Site or your Account, you agree to be bound by the latest published version of this Privacy Policy.
WHAT DOES THE PRIVACY POLICY APPLY TO?
Midasboard Platform, products and services;
Midasboard’s website, including all subpages and successor pages (collectively referred to as the “Site”); and,
any interactions with our clients, prospective clients, Issuers (as defined below) and prospective employees.
This Privacy Policy will continue to apply for as long as we hold your information, including after the termination of any of your products or services with us.
THIS PRIVACY POLICY DOES NOT APPLY TO
The practices of any third party sites or services that may be linked to from our Site or Platform or that may link to our Site; and
the data collection and processing practices of Altrust and Midasboard outside our Site or Platform.
CONSENT
We require your consent to collect, use and disclose your personal information in accordance with this Privacy Policy. Consent may be expressed or implied. Express consent may be given orally or in writing, including electronic transmission. Implied consent is consent that can be reasonably inferred by your action or inaction. By accessing this Site, logging into the Platform, or providing us with the personal information described in this Privacy Policy, we assume you have implicitly provided Midasboard with your consent to collect, use and disclose your personal information in accordance with this Privacy Policy.
You may withdraw or limit your consent to Midasboard’s collection, use and disclosure of your personal information at any time, subject to your legal and contractual obligations you may have to us as a result of our business relationship. You must provide reasonable notice of the withdrawal of your consent. All communications with respect to the withdrawal or limitation of your consent should be directed to our Chief Compliance Officer in writing (see Contact Us). Withdrawing or limiting your consent may adversely affect our ability to provide you services and may in certain circumstances require the closing of your Account.
In some circumstances, Midasboard is entitled, or required, to disclose your personal information without your consent. These circumstances include, but are not limited to:
protecting your health or safety;
the disclosure is necessary for an investigation or proceeding;
the disclosure is required or authorized by law;
the disclosure is required to comply with a subpoena, warrant or order of a court or other body authorized to compel production of the information;
the disclosure is to a public body and relates to an investigation of an offence;
the disclosure is to a lawyer who is representing Midasboard;
the disclosure is required to respond to an emergency; and,
where the personal information is publicly available.
WHAT PERSONAL INFORMATION WE COLLECT
Information you provide to us that enables you to use our services
If you choose to open an Account, you represent that the information you provide to us is accurate and that you will keep such information current at all times during the term of your Account with us. If we believe or suspect that your information is not true, accurate, current or complete, we may deny or terminate your access to the Platform in accordance with our Terms of Use, which are available here.
Biographical information
May include your name, address, phone numbers, email address, birthdate, Social Insurance Number (SIN), or other national or provincial identifiers provided by you when you sign up for an account.
Financial information
May include annual income, net worth, names of financial institutions, and related financial information that we collect from you or your financial institution.
Photo ID
We may collect copies of government-issued identification and a picture of yourself (a “selfie”) that you provide us or one of our service providers for verification purposes.
Questionnaire responses and other regulatory questions
This may include asset holdings and values, and investment knowledge and objectives that you provide in risk information forms we ask you to complete.
Information you provide when you contact us
If you reach out to a customer service agent or advisor you may be asked for information that identifies you (such as your name, address, or a phone number), along with additional information we need to help us promptly answer your question or respond to your comment or concerns. We may record the conversation or retain this information to assist you in the future and to improve our customer service, and product and service offerings.
Employment Information
If you inquire about or apply for a job with Midasboard or any of our affiliates, 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.
INFORMATION AUTOMATICALLY COLLECTED THROUGH YOUR USE OF THE SITE OR PLATFORM
Service Information
We collect information that is generated through your actions when you use our Site, such as your interactions with our products, your preferences or statistics regarding your use of our services, and data on where you are physically located while using the platform.
Cookies and Similar Technologies
Please see our Cookie Policy for more information.
Log Data and Usage Information
In general, you can visit our Site without indicating who you are or submitting any personal information. However, we collect and log the IP (Internet protocol) addresses of all visitors to the Sites and other related information such as page requests, browser type, operating system, and average time spent on the Site. We use this information to help us understand activity, to monitor and improve the Site and to provide security for our users.
Analytics
We may use third parties, such as Google Analytics, to help us gather and analyze information about the areas visited on the Sites in order to better understand, evaluate and improve the user experience and the convenience of the Site. We do not link the information we gather through such analytics to your Account.
PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES
Information from Third Party Service Providers
We may gather information from service providers, for example from credit reporting agencies and other financial institutions (e.g. name, credit history), as part of identity verification or fraud prevention. If you link a bank account to your Account, we will gather transaction level information with respect to the settlement of any Platform transactions you make through your Account. If you are referred to Midasboard by a fund manufacturer or other corporate entity on the Platform (an “Issuer”), or purchase the securities of an Issuer, they will provide us with both general and transaction-specific information about you.
Social Media Information
If you engage with our content through social networking websites, plug-ins and applications, we may collect certain information associated with your social media account (e.g., name, username, email address, profile picture, gender).
HOW WE USE YOUR PERSONAL INFORMATION
In addition to the purposes identified to you before or at the time of collection, the personal information we collect is used for the following purposes, as applicable:
verifying your identity and other information you have provided to us;
determining your eligibility for products and services;
understanding your financial needs and determining the suitability of our products and services for you;
managing your relationship among Midasboard products and Issuers, including opening and servicing your Account, and maintaining accurate and consistent information about you;
helping us manage and assess our risks and operations;
detecting, preventing and suppressing errors, fraud, financial abuse and other unauthorized or illegal activities;
protecting both you and us against errors, fraud or other misrepresentations;
meeting legal and regulatory requirements;
tailoring your Site experience, including making recommendations for Midasboard products or services;
de-identifying your information by removing personal identifiers such as your name, address and account numbers. This information will not be used to identify individuals, and may be used for analytics and reporting, developing and improving our products and services, and identifying trends and insights that may be of value to us and our clients; and,
as otherwise required or permitted by applicable law.
WHERE WE SEND YOUR PERSONAL INFORMATION
We do not sell your personal information.
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, printing, marketing and advertising, hosting, cloud storage, data analysis, legal and accounting.
We use various service providers to specifically assist us with identity verification. These service providers may review the personal information documentation you provide us to confirm its authenticity, or may compare your information in our control with information about you from other sources to confirm your identity when creating or logging in to your Account. We may use biometric ID verification providers, such as Plaid, to confirm the authenticity of photo identification. We take these steps to verify your identity very seriously in order to detect, prevent and suppress errors, fraud, financial abuse and other unauthorized or illegal activities. Your personal information will be sent to Plaid’s U.S.-based servers.
Partners: We may share your personal information with Issuers that offer their securities on the Platform, and we or they may share your information with the Issuers’ service providers in order to respond to your inquiries and transaction requests. We may also enter into partnership or referral arrangements with third parties who seek to provide you with products or services (“Referrals”). We do not provide your personal information as part of a Referral without your consent and we require similar safeguards from our service providers and Issuers.
Successor Business: We may share personal information with any successor to all or part of our business. For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of Altrust/Midasboard or part of its business (or in anticipation of such an event), we may share your personal information as part of that transaction. We will disclose personal information in these circumstances only when the third parties agree to use such personal information solely for the purposes of evaluating and carrying out the transaction and, with respect to that information, to act in a manner consistent with the principles articulated in this Privacy Policy. You acknowledge that such transfers may occur, and that any direct or indirect acquirer of us or our assets may continue to use your personal information as set forth in this Privacy Policy.
Securities Regulations: We may share your personal information, including name, contact information, and transactions you have made in your Account with the relevant Issuers 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.
For regulatory purposes, regulatory bodies such as the Ontario Securities Commission or FINTRAC may require access to personal information of current or former clients that has been collected or used by Midasboard. Regulators may use the information for such purposes as:
surveillance of trading-related activity;
sales, financial compliance, trade desk review and other regulatory audits;
investigation of potential regulatory and statutory violations;
regulatory databases;
enforcement or disciplinary proceedings;
reporting to securities regulators; and,
information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.
Because Midasboard is a regulated entity, unless you provide consent to the sharing of information with these bodies for these purposes, Midasboard cannot provide financial services to you.
Legal: We and our affiliates, and 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. This may include lawful access requests by Canadian, United States, or other foreign courts, law enforcement, or governmental authorities for the purposes of detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, U.S., or other law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Aggregate or Anonymized Information: We may share aggregate information or anonymized information with third parties, including vendors, partners and consultants, to better understand how and how often people use the Site and Platform and/or their services or websites. In addition, these third parties may share with us non-private, aggregated, personal or non-personal information about you that they have independently developed or acquired.
Other: We may share personal information for other reasons we may describe to you and for which, where required by applicable law, we have obtained your consent or as permitted by law.
HOW WE PROTECT YOUR INFORMATION
We implement safeguards
We maintain 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. We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign confidentiality agreements that oblige 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 elements of your personal information is protected with a password you select for your privacy and security. You need to prevent unauthorized access to your Account and personal information by selecting and protecting your password appropriately and limiting access to your computer and browser such as by signing off after you have finished accessing your Account. 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). If you become aware of any unauthorized access to or use of your Account, you are required to notify us immediately.
Despite the safeguards we take to protect the personal information submitted to us, no method of security is entirely secure. We cannot promise that your use of the Site or Platform will be completely safe. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of personal information at any time. We encourage you to use caution when transmitting personal information over the Internet.
We don’t retain information longer than necessary
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. As an OSC registrant, the general requirement for retaining client records is typically seven years. This is in accordance with the record-keeping requirements outlined in National Instrument 31-103, specifically under section 11.6, which governs record-keeping by registered firms. When we no longer require your personal information, we will either destroy or erase it, or we will make it anonymous such that it cannot be associated with or tracked to you.
We limit access to clients’ personal information
We store personal information electronically in cloud storage, and we may also keep reports generated from such data on the local computers of our employees in encrypted form. Only authorized persons have access to such data, 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 require similar safeguards from our service providers
Our service providers are transferred the information they need to perform their designated functions and are committed to maintaining your confidentiality. Our service providers are not permitted to use your information for any unauthorized purpose. Your personal information may be maintained and processed by third party service providers outside of Canada, in the United States, or in other jurisdictions. In the event personal information is transferred to the U.S. or another 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.
STEPS YOU CAN TAKE TO PROTECT YOUR PERSONAL INFORMATION
To protect your Account, we encourage you to:
use a long and unique password for Midasboard - do not use the same password across different Sites or apps;
never share your password with anyone;
limit access to your computer, phone and browser; and,
log out once you have finished using Midasboard on a shared device.
We also encourage you to review your browser privacy settings and generally be aware of your online privacy. You can find educational resources from the Privacy Commissioner of Canada and a knowledge base and specific recommendations at the non-profit Privacy Guides.
Links to third party websites and services
We may provide links to websites or other online platforms operated by third parties. If you click on a link to an unaffiliated third party website, you will be taken to website(s) that we do not control, and you should review their privacy and security policies and other terms and conditions. This Privacy Policy does not apply to the privacy practices of third party website(s). Read the privacy policy of other websites carefully before you submit any personal information to these third party website(s). We are not responsible for actions, omissions or practices of third party website(s). Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or their owners or operators. This also applies to websites that offer links to the Midasboard Site. Furthermore, explicit prior authorization must always be obtained for a link leading from an external website to the Midasboard Site.
CHILDREN’S PRIVACY
No Children’s information. The Site and Platform are meant for adults. We do not seek to collect personal information from minors. If the birthdate information provided by a user indicates the individual is a minor, we will delete the personal information from that user record. If you are a parent or legal guardian and think your minor child has given us personal information, please contact us at the address below. Parents and guardians may learn more about how to protect children's privacy on-line here.
YOUR RIGHTS OVER YOUR INFORMATION
We will make all reasonable efforts to ensure that any personal information we collect and keep is as accurate, complete and as up-to-date as required for the identified purposes. To do so, we will rely on you to provide us with accurate information and to inform us of changes, such as changes in your contact information. You have the right to access, update, and correct personal information in Midasboard’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. Otherwise, if you wish to request access, updating and corrections of inaccuracies in personal information in our possession or control, you may send a written request to this effect to support@midasboard.com. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
Midasboard reserves the right to decline to provide access to personal information in certain circumstances. These include, but are not limited to, circumstances where the information requested:
would disclose personal information, including opinions, about another individual;
would disclose Midasboard’s trade secrets or other confidential business information;
is subject to lawyer-client privilege;
is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information;
does not exist or cannot be found;
could result in serious harm to the individual requesting it, serious harm to the life, safety or health of another person, or serious emotional harm or embarrassment to another individual;
may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions; and,
may be, or is required to be, withheld by other legislation.
Where information requested will not or cannot be disclosed, Midasboard will provide the reasons for non-disclosure.
Marketing Communications
From time to time, we may send you email, SMS text messages and other communications about Midasboard products, services, or events that may be of interest to you, as well as products, services or events of Issuers. 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@midasboard.com.
CLOSING YOUR ACCOUNT
Should you ever desire to close your Account, you may do so by submitting a written request to the address listed below. If you close your Account, any association between your Account and information we store will no longer be accessible by you through your Account, unless otherwise specified by us. Please note that we may need to verify that you have the authority to delete the Account. After the closure of your Account, we will store your information for such period of time of time as is required by applicable law.
CONTACT US
Midasboard's Chief Compliance Officer is responsible for ensuring that Midasboard adheres to its Privacy Policy. If you would like to make a request, a complaint or ask a question about how we process your personal information, please contact our compliance team at support@midasboard.com, or write to us at:
Altrust Investment Solutions Inc.
Attn: Chief Compliance Officer
150 King Street West, Suite 327
Toronto, Ontario M5H 1J9
INTERPRETATION OF THIS PRIVACY POLICY
Our Chief Compliance Officer has the responsibility and authority to interpret and administer this Privacy Policy. This Privacy Policy does not create or confer any additional rights or obligations to those imposed under provincial or federal privacy legislation. Should there be, in a specific case, any inconsistency between this Privacy Policy and applicable provincial or federal privacy legislation, then this Privacy Policy will be interpreted to give effect to and comply with such privacy laws.
WE MAY UPDATE THIS PRIVACY POLICY
We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. We will notify you of any material changes to our Privacy Policy as required by law such as by posting an announcement on the Site or sending you an email. We will also post an updated version on our Site. Please check our Site periodically for updates to this Privacy Policy. You are bound by any changes to the Privacy Policy when you use the Site or Platform after such changes have been first posted. If you do not agree with any updates to this Privacy Policy, please do not access or continue to use the Site or the Platform.