REGULATION :

Botica Financial Group/ Botica Capital Management Inc.

Autorité des marchés financiers (AMF)

VERIFICATION :

Botica is subject to an annual audit by the various regulatory agencies. In addition, an audit of our books and records is performed by an independent firm.

The compliance officer enforces regulatory requirements in order to protect its investors.

The Compliance Office monitors compliance with all regulations and laws governing mutual funds, as well as internal policies and procedures of BOTICA . This office is developing compliance tools such as Know Your Client (KYC) which allows representatives to have a thorough knowledge of investment objectives and risk tolerance of their clients.

PROTECTION OF INVESTMENTS

Easy monitoring of investments and rates of return by clients

Account statements are sent to clients by BOTICA on a quarterly basis or the client can choose to have online access with written authorization.

In addition, most fund companies also send a statement of account.

CONFIDENTIALITY

Protection of Personal Information

BOTICA Financial Group Inc./BOTICA Capital Management Inc. acts as an intermediary, between the insurers and independent representatives or between mutual fund companies and mutual fund representatives that are attached to BOTICA Capital Management Inc.

We value our clients as a company working in the field of financial services, our clients place their trust in us by providing us with their personal information. We are committed to maintaining their trust and protecting their personal information.

We collect personal information in compliance with the law and best commercial business practices in order to provide services and make ethical decisions. We limit the information we collect to what is necessary for or related to these purposes:

We respect the ten privacy principles based on the laws of privacy of the federal government, the protection of personal information and electronic documents.

Personal information shall be as accurate, complete and current as necessary for the purposes for which they are intended.

  1. Responsability: An organization is responsible for personal information under its control and shall designate one or more persons to ensure compliance of the organization with the following principles.
  2. Determination for collection of information: The purpose for which personal information is collected shall be identified by the organization at or before the time the information is collected.
  3. Consent: The consent of the person must be informed of the collection, use or disclosure of personal information, except where inappropiate.
  4. Limitation of collection: The collection of personal information must be limited to what is necessary for the purposes identified by the organization. The information must be collected by fair and lawful means.
  5. Limitation of usage, communication and conservation: Personal information should not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
  6. Exactitude: Personal information shall be as acurate, complete and current as necessary for the purposes for which they are intended.
  7. Security Measures: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
  8. Transparency: An organization must ensure to inform individuals about its policies and practices relating to the management of personal information.
  9. Access to Personal Information: Upon request, one person must be informed of the existence, use and disclosure of personal information and provide him/her access to that information. Anyone should be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
  10. Request for Information and Complaints: Challenging Compliance : Any individual shall be able to complain about the non-respect of the above mentioned principles to the designated individual for the respect of the organization.

Collection and utilisation

We collect the information necessary for us to accomplish the task at hand, be it insurance, investment or financial planning.

Personal information is information about you specifically. We will use fair and lawful means to collect personal information. We only collect information that is relevant and consistent with the objectives of collection. Whenever possible, we will gather the necessary information directly from the client or his authorized representative (s), in applications and forms, by other means of correspondence, such as telephone, mail or Internet, and thanks to their business relationship with us.

What we need to know and why

We collect information from our clients and about them, with their consent or as required or permitted by law. In general, we collect personal information such as their name, address, phone number and other identifying information such as their social insurance number (SIN), number of other identification cards as permitted in the regulation or birth date.

The type of information we collect depends on the type of product or service. The information gathered can be financial, which includes information such as the workplace, annual income, assets and liabilities. It can also be investments or related guidance, information needs on items such as your financial objectives and retirement. If the client is applying for insurance or group insurance, it may also contain information or information related to lifestyle, such as their travel history, occupation, plans, conduct or bin folder judiciary.

Consent

The consent to create a file and collect and keep personal and financial information has to be signed by the client and placed in their file.

Protection of Personal Information

The owners, employees, (others) of ” Company Name ” have access granted to the client information and should understand the need to keep information confidential and protected at all times. Our training methods clearly communicated to all employees to use the information only for the defined intended use.

Staff is required to sign a confidentiality agreement at the beginning of employment.

Conservation of Personal Information

We will keep customers’ personal information in our files as long as necessary to fulfill the identified purposes, or as required or permitted by law.

Choice of confidentialty

Clients can request copies of our privacy policies and procedures at any time.

Clients can request access to their information. We must respond to this request as soon as possible but no later than 30 days after receipt of the request.
Clients can withdraw their consent at any time by contacting our Chief Compliance Officer. However, they will be informed that failure to provide adequate information may prevent us from completing the task at hand.

Clients can file complaints about our privacy procedures, as well as a breach of our privacy policy. Complaints must be made in writing or by email and sent to the Compliance Officer. The Chief Compliance Officer will contact the client to get all the details.

The Chief Compliance Officer will then review the circumstances of the complaint and determine if our privacy policy should be amended:

Louise Giguère Chief Compliance Officer

Botica Financial Group Inc. / BOTICA Capital Management Inc.

950-1450, rue City Councillors

Montréal (Québec) H3A 2E6

l.giguere@botica.ca

Exception to Client Access

BOTICA will have to refuse access to personal information :

  • If he/she disclosed personal information about another person unless there is consent or a life-threatening situation.
  • If the organization has provided information to a government institution for law enforcement or for reasons of national security. Upon request, the government institution may ask the organization to refuse access or not to reveal that information was published. The organization should refuse the request and notify the Privacy Commissioner. The organization can not inform the individual of the disclosure to the government institution or the institution was informed of the request, or the Privacy Commissioner was informed of the refusal.

Organizations may deny access to personal information if the information falls within one of the following:

  • Attorney-client privilege
  • Confidential business information
  • disclosure could adversely affect the life of an individual or safety
  • it was collected without the knowledge of the individual or consent to ensure availability and accuracy , and the collection was to investigate a breach of an agreement or a contravention of federal or provincial law ( the Commissioner must be notified )
  • it was produced as part of a formal dispute resolution process