Privacy Policy
1. Introduction
This Privacy Policy explains how KYP Manager ("KYP Manager", "we", "us") collects, uses, shares and protects personal information in connection with the KYP Manager platform and client portal (the "Service"). We provide the Service to investment advisory firms ("Firms"). If you are a client of a Firm, that Firm is responsible for the personal information it holds about you and for how it uses the Service; we process that information on the Firm's behalf. Your Firm's own privacy practices apply in addition to this Policy.
2. Information we collect
Information you or your Firm provide. Account details such as your name, email address and role, and the records your Firm keeps in the Service, which may include client profiles and contact details, financial account information, planning and insurance records, notes, messages and uploaded documents.
Information collected automatically. When you use the Service we collect the technical and usage information needed to operate, secure and support it, such as device and browser information, log data and records of activity within your account.
Cookies and similar technologies. We use only the cookies and browser storage needed to sign you in, keep your session secure and remember your preferences. We do not use advertising or third-party analytics cookies.
3. How we use information
- To provide, maintain, support and improve the Service.
- To authenticate users, secure accounts, and detect and prevent fraud, abuse and security incidents.
- To send service communications, such as notifications and account or security messages.
- To help Firms meet their legal, regulatory and recordkeeping obligations.
- To comply with applicable law and enforce our terms.
We do not sell personal information and we do not use it for advertising.
4. How we share information
With your Firm. Information is available to your Firm and to the staff it authorizes, according to the roles and settings the Firm configures. Where your Firm links your record with a household member's, certain information may be visible to that household member as the Firm configures.
At your Firm's direction. Your Firm may share specific documents with third parties you work with, such as an accountant or lawyer, through secure, time-limited links.
With service providers. We use third-party providers to host, secure and support the Service, to deliver email, to supply market data, and, where a Firm chooses to enable them, to support optional features such as calendar synchronization and document-processing or drafting assistance. Providers may use information only to deliver their services to us and are bound by confidentiality and data-protection obligations.
For legal reasons. We may disclose information where required by law, to respond to lawful requests, or to protect the rights, property or safety of KYP Manager, our Firms or others.
Business transfers. If KYP Manager is involved in a merger, acquisition or sale of assets, information may be transferred as part of that transaction, subject to this Policy.
We do not share one Firm's information with any other Firm using the Service.
5. International transfers
Our primary data storage is located in Canada. Some of our service providers process information in other countries, including the United States. Information processed outside Canada is subject to the laws of those jurisdictions and may be accessible to their governments, courts and law-enforcement agencies under lawful process.
6. Security
We maintain administrative, technical and physical safeguards appropriate to the sensitivity of the information we hold, including encryption in transit and at rest, multi-factor authentication, role-based access controls and activity logging. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Our Security overview describes our approach.
7. Data retention
We retain personal information for as long as your Firm maintains its account with us and as needed to provide the Service, and thereafter as required to meet the legal, regulatory and recordkeeping obligations that apply to your Firm. Firms may delete client records from the Service, subject to those obligations. Deleted information may persist in backups for a limited period.
8. Your rights and choices
Subject to applicable law, you may request access to or correction of your personal information, or withdraw your consent to its use, by contacting your Firm, which controls the records held about you. Clients with portal access can also view a log of activity on their documents within the portal.
9. Children
The Service is intended for use by adults. Firms are responsible for any records they keep about minors, such as beneficiaries of savings plans.
10. Changes to this Policy
We may update this Policy from time to time. We will post the updated Policy on this page and revise the date above, and we will notify Firms of material changes.
11. Contact
Questions about this Policy or about your personal information should be directed to your Firm, which can reach the platform operator on your behalf.