Privacy Policy

1. About This Policy

Vincenzo Pace is an Investment Advisor with Manulife Wealth Inc. and a Financial Security Advisor with Manulife Wealth Insurance Services Inc., working from an office in Dorval, Quebec. In this policy, "we", "us" and "our" refer to the practice of Vincenzo Pace - Manulife Wealth.

This Privacy Policy explains how we collect, use, disclose and protect your personal information when you visit www.vincenzopace.ca (the "website"), contact us, or work with us on retirement planning, investment advice and insurance solutions.

We handle personal information in accordance with Quebec's Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1; in French, Loi sur la protection des renseignements personnels dans le secteur privé), as amended by Law 25, and with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

By using this website or contacting us through it, you agree to the practices described in this policy.

2. Privacy Officer

We have designated a Privacy Officer, the person responsible for the protection of personal information in this practice:

You can contact our Privacy Officer with any question, request or complaint about how we handle your personal information.

3. Information We Collect

We collect only the personal information we need for the purposes described in this policy. Depending on how you interact with us, this may include:

• Identification and contact information: your first name, last name, email address, telephone number and, when relevant, your mailing address.
• Your preferences and consents: whether you have agreed to receive text messages or email communications from us, and the choices you make about them.
• The content of your communications: what you write in the website contact form, in an email, in a text message or during a meeting with us.
• Planning information: when you engage us, the information needed to advise you, which may include your financial objectives, your family and employment situation, your income, assets and liabilities, your existing insurance coverage, your investment knowledge and your risk tolerance.
• Application information: if you apply for a position with us, your name, email address, telephone number, the role you are applying for and the content of your message.
• Technical information about your visit: described in section 4.6.

Please do not send sensitive information, such as your social insurance number, account numbers or banking details, through the website contact form, by ordinary email or by text message. We will tell you the secure way to provide that information when it is required.

4. How We Collect It

4.1 Directly from you

Most of the information we hold comes from you, during meetings, phone calls, emails, text messages and the forms you complete when you become a client.

4.2 Website contact form

The contact form on our home page asks for your first name, last name, phone number and email address, and it includes two optional consent checkboxes for text messages. When you submit it, the form is processed by FormSubmit (formsubmit.co), a third-party form service, which delivers your submission to our business email address. We then use it to answer you.

The form also runs two simple anti-spam checks: a hidden field that a person never fills in, and a check on how quickly the form was submitted. These checks do not use cookies and are not used to identify you.

4.3 Text message consent

The contact form includes two separate checkboxes: one for transactional text messages and one for non-marketing text messages such as appointment reminders. Both are optional, and neither is required in order to send us a message. If you tick a box, you consent to receive those messages at the number you provide. Message frequency may vary, and message and data rates may apply. You can reply STOP at any time to stop receiving them, or HELP for assistance. The full text message terms are set out in our Terms and Conditions.

4.4 Newsletter sign up

The email sign up field on our home page sends the email address you enter to Mailchimp, the email marketing platform that hosts the mailing list. You can unsubscribe at any time using the link at the bottom of any email you receive.

4.5 Career applications

The form on our Career page collects your first name, last name, email address, telephone number, the role you are applying for and your message. Like the contact form, it is processed by FormSubmit and delivered to our business email address. We use it only to consider your application and to contact you about it.

4.6 Technical information

This website is hosted on Microsoft Azure Static Web Apps. When you visit the site, the hosting service automatically processes technical information such as your internet protocol (IP) address, your browser type, the date and time of your request and the pages requested. This information is needed to deliver the website, administer it and keep it secure. We do not combine it with other information to identify you, and we do not use it to track your browsing or to build a profile about you.

4.7 Booking a call

When you use a Schedule a Call link, you are taken to Calendly, a third-party scheduling service. The information you enter there, such as your name, your email address and the time you select, is collected by Calendly under its own privacy policy and sent to us so that we can hold the meeting.

5. Why We Use It

We use your personal information for the following purposes:

• To answer your questions and respond to the messages you send us.
• To arrange and hold meetings with you.
• To understand your situation and your objectives so that we can recommend suitable retirement, investment and insurance strategies.
• To open, service and administer the accounts and policies you hold through Manulife Wealth Inc., Manulife Wealth Insurance Services Inc. and the product providers you choose.
• To send you the communications you asked for, such as the newsletter, appointment reminders and other service messages, where you consented to receive them.
• To consider your application if you apply for a position with us.
• To meet our legal, regulatory and professional obligations, including the client identification and record keeping requirements that apply to the investment and insurance industry.
• To keep this website and our communications secure, and to improve them.

We do not sell your personal information. We will not use it for a new purpose that you would not reasonably expect without asking for your consent first, unless the law permits or requires it.

6. Consent and Withdrawal

We collect, use and disclose your personal information with your consent, unless the law allows or requires us to do otherwise. Your consent may be express, for example when you tick a text message consent box or sign an account form, or it may be implied by the circumstances, for example when you send us a message and expect a reply.

We ask for your express consent before collecting sensitive personal information and before using your information for a purpose you would not reasonably expect.

You may withdraw your consent at any time by contacting our Privacy Officer, subject to legal and contractual restrictions and to reasonable notice. Withdrawing your consent may mean that we can no longer provide certain services to you. Some information must be kept even after consent is withdrawn, because record keeping obligations require it.

You can also stop receiving marketing or text messages without withdrawing your consent to everything else. Reply STOP to a text message, use the unsubscribe link in an email, or simply ask us.

7. Sharing Your Information

We share your personal information only when it is necessary, and only with:

• Manulife Wealth Inc. and Manulife Wealth Insurance Services Inc.: the investment dealer and the insurance agency through which our services are offered, and the service providers they use. See section 8.
• Insurers, fund managers and other product providers: when you apply for or hold a product through us.
• Service providers: third parties that help us operate this website and communicate with you, such as our hosting provider, our form processing service, our email platform and our scheduling tool. Section 9 lists the services this website uses.
• Other professionals you ask us to work with: for example your accountant, notary or lawyer, with your authorization.
• Legal and regulatory recipients: regulators, self-regulatory organizations, tax authorities, courts and law enforcement, when the law requires or permits disclosure.

We do not sell or rent your personal information, and we do not share it with marketing partners without your explicit consent. We ask the service providers we engage to protect the information they handle for us and to use it only for the purposes we specify.

8. Manulife Wealth Inc.

Investment dealer dealing representatives ("Investment advisors") registered with Manulife Wealth Inc. offer stocks, bonds and mutual funds. Insurance products and services are offered through Manulife Wealth Insurance Services Inc.

When you become a client, the information in your account and policy files is collected, held and administered by those companies. Their handling of that information is governed by the Manulife privacy policy rather than by this one. You can read it at manulife.ca, and the same link appears in the legal banner at the foot of this page.

This policy covers the information we collect through this website and directly in the course of our work with you. If you are unsure which company holds a particular piece of information, ask our Privacy Officer and we will tell you.

9. Third-Party Services

This website relies on the following third-party services:

• Microsoft Azure (hosting): the website is hosted on Microsoft Azure Static Web Apps. Microsoft processes technical information, such as IP addresses, in order to deliver the site. See the Microsoft Privacy Statement.
• FormSubmit (contact and career forms): submissions from the contact form and the career form are processed by FormSubmit and delivered to our business email address.
• Mailchimp (newsletter): the email sign up field on the home page submits your email address to Mailchimp. See the Mailchimp Privacy Policy.
• Calendly (scheduling): the Schedule a Call links open a booking page operated by Calendly, which collects the details you enter there. See the Calendly Privacy Notice.
• Google Fonts and Google Hosted Libraries: the website loads its fonts, and on the home page certain script files, from Google servers. When your browser requests those files, Google receives your IP address and basic information about your browser. See the Google Privacy Policy.
• Public content delivery networks: the website also loads script files from cdnjs and jsDelivr. When your browser requests those files, those services receive your IP address.
• Client Portal: the Client Portal button opens the Manulife Wealth sign in page. What you do there is governed by Manulife's own terms and privacy policy.

Our pages also link to other websites, including Google Maps, LinkedIn, CIRO and CIPF. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy policies.

10. Transfers Outside Quebec

Several of the service providers listed in section 9 are operated by companies based outside Canada. As a result, your information may be processed or stored outside Quebec, including in the United States.

As Quebec law requires, before communicating personal information outside Quebec we assess whether it will receive adequate protection. Information held in another country is subject to the laws of that country and may be accessible to its courts, its law enforcement agencies and other authorities.

11. Cookies and Analytics

This website does not set cookies of its own, and it does not use analytics, advertising or tracking tools. There is no Google Analytics, no tag manager, no advertising pixel and no social media tracking script on this site, and we do not follow your browsing from page to page or across other websites.

The website does load fonts and script files from the third-party services listed in section 9, and those requests reveal your IP address to them.

Third-party websites you reach from our links or buttons, such as Calendly, the Client Portal and the Manulife websites, may use cookies. Their use of cookies is governed by their own privacy policies. You can also configure your browser to block or delete cookies.

12. How We Protect It

We take reasonable measures to protect personal information against loss, theft and unauthorized access, use, disclosure, copying or modification. These measures include:

• Designating a Privacy Officer.
• Limiting access to personal information to the people who need it to do their work.
• Administrative and physical security measures at our office.
• Raising awareness and providing training for the people who work with us.
• Serving this website over an encrypted (HTTPS) connection.
• Selecting service providers that undertake to protect the information they handle for us.

If a confidentiality incident involving your personal information presents a risk of serious injury, we will notify you and the Commission d'accès à l'information du Québec, as the law requires.

Despite these precautions, no method of transmission or storage is completely secure. Email and text messages in particular travel over networks we do not control. We make every effort to protect personal information, but we cannot guarantee the security of the information you send to us, or that we send to you, by those means.

13. How Long We Keep It

We keep your personal information only as long as necessary for the purposes described in this policy and to meet our legal, regulatory and professional obligations, including the record keeping requirements that apply to investment and insurance business. The applicable period depends on the type of information and on the obligation that applies to it.

When the information is no longer needed for those purposes, it is destroyed or anonymized. Records held in your account and policy files by Manulife Wealth Inc. and Manulife Wealth Insurance Services Inc. are retained in accordance with those companies' own retention rules.

14. Your Rights

Subject to applicable law, you have the right to:

• Access: be told whether we hold personal information about you, and receive a copy of it.
• Correction: have information that is inaccurate, incomplete or ambiguous corrected, and have information that is not necessary removed.
• Withdraw consent: as described in section 6.
• Portability: receive the computerized personal information you provided to us in a structured, commonly used technological format, or ask us to send it to another organization, where the law provides for it.
• Deletion: ask us to delete your information, where the law allows it.
• De-indexing: ask that a link giving access to information about you stop being disseminated or be de-indexed, in the circumstances provided by Quebec law.
• Complain: as described in section 16.

To exercise a right, contact our Privacy Officer using the details in section 16. We may ask you to confirm your identity before acting on your request, and we will respond within the time limits set by applicable law, which is generally 30 days. If your request concerns an account or a policy held with Manulife Wealth Inc. or Manulife Wealth Insurance Services Inc., we will help you direct it to the right place.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, in the services we use or in the law. The "Last Updated" date at the top of this page shows when it was last revised. Significant changes will be communicated by a notice on this website or by email where that is appropriate. We encourage you to review this page from time to time.

16. Contact Us and Complaints

For any question, request or complaint about this policy or about how we handle your personal information, contact our Privacy Officer:

We will acknowledge your request or complaint and respond to it. If you are not satisfied with our response, you may file a complaint with:

• The Commission d'accès à l'information du Québec, the authority responsible for the protection of personal information in Quebec.
• The Office of the Privacy Commissioner of Canada.

Concerns about an account or a policy may also be raised directly with Manulife Wealth Inc. or Manulife Wealth Insurance Services Inc.