Our Privacy Philosophy

At FOREST personal information is strictly private and confidential. We handle it with great care and discretion, and we ensure compliance with the privacy legislation.

We value the trust that you have placed in our organization and are committed to prioritizing commitment to maintaining the accuracy, confidentiality, and security of personal information.  We will not collect, use, or disclose your personal information without your informed consent, unless required or permitted to do so by law. Read through this Privacy Policy (“Privacy Policy”) so you understand how we use, share, and store your data.

PART I

1. Our policy

In this Privacy Policy, “Forest”, “we”, or “us” refers to Forest. All services mentioned are services provided by Forest.

“You” refers to anyone who visits our website, our clients and anyone who engages with our services. It’s our duty to inform you about what we’re doing with your personal information and why, and ensure you are properly informed so you can give us meaningful consent.

For the purposes of this Privacy Policy, “personal information” means information that: (i) can identify an individual directly; or (ii) is information about an identifiable individual. This does not include information that is used solely for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession.

2. Agreeing to the terms of our privacy policy

By providing personal information to Forest, using our website www.davidforest.com (the “Website”), or engaging with our social media, you are consenting to our use, collection, and disclosure of your personal information in accordance with the terms of this Privacy Policy. Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to Forest’s collection, use, and disclosure of personal information in accordance with this Privacy Policy.

You have the right to withdraw your consent from us collecting and using your personal information, but this may limit our ability to provide you with our services or products, if applicable. See below for details around same.

3. Types of information collected

The type of information that may be collected includes but is not limited to:

• Contact information: this information allows us to identify you as well as send you materials. It lets us communicate with you for instructions and requests. It includes your name, mailing address, email address, and telephone number;
• Banking information: including your bank account information, billing address, or other banking and financial information required to complete your order;
• Date of birth: this information allows us to fulfill our legal obligation to establish your identity and also helps protect against error, identity theft, and fraud;
• Employment History: we collect this information to better understand your unique financial situation and investment needs, and to help us fulfill our suitability obligations;
• Social Insurance Number: we obtain your Social Insurance Number (SIN) for tax reporting purposes. We may also use your SIN for credit reporting or monitoring purposes, and to distinguish you from other persons or clients;
• Information required to comply with applicable laws and regulations: including your date of birth, home address, marital status, employment history, criminal record history, bankruptcy history, disciplinary history, passport, driver’s license, SIN, Tax Identification Number (TIN), investment history, account numbers, if there is a spousal account or not, performance of investments, size of investments, etc.;
• Profile information: includes your username and password, requests made by you, your interests, preferences, feedback, and survey responses;
• Transaction information: includes details about payments to and from you and other details of subscriptions and claims you have requested from us, including product information and dollar values;
• Marketing and communications information includes communication preferences and your preferences in receiving marketing or other communications from us and third parties;
• Computer information: this includes information like device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, user behavior, length of time spent on the services, and frequency of use; and
• Other information you voluntarily provide to us, our employees, our service providers or our contractors.

Information will be collected by fair and lawful means. We won’t take more information than we need, and you decide how and what you want to share.

4. Why we collect your information

At Forest, we collect and use personal information for reasons like:

• Fulfillment of subscription/claim requests and other services: to fulfill subscription/claim requests and access services with us;
• Business and website operations: to administer and protect our business and this Website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
• Marketing and advertising: to be presented on our Website. We may also administer surveys, contests, draws, raffles, offer tailored content, and other promotional materials to you based on your interests;
• Regulatory requirements: complying generally with all laws and applicable regulatory requirements, including maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions and embargo laws); and
• Business development and market research: we use data to understand demographics, interests, usage patterns, and other characteristics of customers and to track and analyze trends and patterns.

We will obtain your consent before proceeding with any other purpose not identified in this Privacy Policy.

5. How we collect your information

Personal information may be collected in a number of ways, including through our Website, in person, by mail, by email, by telephone, from our applications or other software, and from third parties such as insurance companies whom you have authorized to disclose personal information to us. If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent.

a) Cookies

We may also collect information through “cookies” on our Website. Cookies are small text files inside your computer that contain a unique identifier, allowing us to recognize you when you visit our Website again.  This helps us tailor our content to meet your needs and for advertising purposes.  You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies.  However, if you select this setting you may be unable to access certain parts of our Website.  By accepting cookies and continuing to visit or use our Website, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this Privacy Policy.

Cookies can be used to: (i) recognize you when you visit the Website, remember your preferences, and give you a personalized experience that’s in line with your settings, (ii) make your interactions with the website faster and more secure, and (iii) bring you advertising and customized experiences through personalization.  Further, cookies are used for authentication, security, and research.

Below explains the reasons we use each type of cookie on our website.

	Essential cookies We use essential cookies to ensure the proper functioning of our website. These cookies are required for basic functions such as browsing the pages of our site and accessing secure areas. It is not possible to deactivate these cookies.
	Preference cookies We make use of “preference cookies” in order to identify you when you make future visits to our website, so that we can store your preferences and permissions. In particular, we use a persistent cookie to save your basic information, such as recent searches or your preferred language.
	Analytics cookies We use analytics cookies to generate aggregated statistical data relating to the visit frequency and behaviour of visitors to our website. FOREST. uses Google Analytics to obtain basic information such as the number of visitors and the times of the day with the most visits, as well as search terms used. Google Analytics helps us better understand the users who interact with our website. The data collected also include elements such as your IP address, geographic location, information about your browser, device identifiers and the sites you have visited before and after visiting our site.
	Advertising cookies  Advertising cookies have an important role to play in enabling us to offer ads adapted to your preferences and interests. They also help limit the frequency with which you are shown a particular ad, let us evaluate the effectiveness of our ad campaigns and content as well as the traffic generated by emails so we can improve our offer and clarify the purchase journey of our clients, and lastly they help us provide a personalized experience.

 

b) Social media

If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our Website or other applications, your communications may be viewable by the public.

6. Who we share your information with

Forest may share your information with third parties. Forest will do so to support with providing our services, administering our business, and for such other purposes as set forth below, including:

• With your consent and permission, we may share your financial information with mutually acceptable professionals such as accountants and lawyers whose services are retained to meet your goals and objectives;
• Administrative and technical support: including cloud storage providers, IT support, and data analytics providers;
• Public media and marketing: including media networks and companies we use for public broadcasting, advertising, marketing, public relations, and press releases;
• Financial institutions and payment processors: we do not store your banking or other financial information in connection with the fulfillment of subscription/claims redemption requests. This is shared directly with our third party financial institutions and payment processors as applicable, all of which are separate legal entities, to provide you with a range of products and services; and
• Securities and tax regulators: including applicable governmental and regulatory entities.

If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.

7. Accuracy

We make every reasonable effort to keep your personal information as accurate, complete and up to date as necessary. We encourage you to verify the accuracy and completeness of your personal information in our records.

Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis.  In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.

8. Protecting Your Personal Information

Our employees and contractors understand the importance of keeping your information private.  All employees and contractors are expected to maintain the confidentiality of personal information. Every employee signs a confidentiality agreement to never discuss your personal information outside our office. Our confidentiality agreement binds them even if they leave FOREST.

To ensure that your personal information is protected, we utilize security safeguards that are on par with industry standards. We keep electronic files and paper document in a secured environment with restricted access and use.

Despite all of the foregoing security measures, online storage and online communications are not entirely secure. We encourage all individuals to provide only the information they are comfortable with providing a third party, keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible.  As a community, we can all help keep it safe.

9.  Data Retention

We shall retain Personal Information only as long as necessary for the fulfillment of the purposes for which it was collected. Where Personal Information is no longer required to fulfill the purpose for which it was collected, it will be destroyed, erased, or made anonymous, provided there are no legal requirements for its continued retention.

10. Opting-out

You may withdraw your consent for our use and collection of your personal information at any time, however this may limit our ability to provide services or products to you, if applicable.

To withdraw consent, please contact us at the contact information set out at the end of this Privacy Policy.  Any withdrawal of consent will apply thereafter and not to information handling practice that have been previously undertaken based on prior consent.

You may opt-out of use of cookies through your browser settings.

11. Updating this Privacy Policy

FOREST strives to evolve to meet our clients’ needs and expectations, and that means our services, how we offer our products/services and how we communicate information may change.  With that in mind, we review our privacy practices from time to time, and our information handling practices may change. If this Privacy Policy materially changes, we will take reasonable measures to notify you of these changes, including posting a copy of the revised Privacy Policy on our website. Your continued use of our Services following notification of any material change and/or your continued access to our website following the posting of any changes to this Privacy Policy shall constitute your acceptance of those changes. You may determine when this Privacy Policy was last updated by referring to the date found at the bottom of this Privacy Policy. If at any point you do not agree with the terms of this Privacy Policy, you must not use the Forest platform, Website, or services. You may also contact us if you would like us to send you a copy of the most current version of this Privacy Policy.

12. Website and Apps governed by this Privacy Policy

Our Website and any of our applications available from our Website or third party platforms are governed by the provisions and practices stated in this Privacy Policy.  Our Website and such applications may contain links to third party sites or applications that are not governed by this Privacy Policy.  Although we endeavor to only link to sites or applications that share our commitment to your privacy, please be aware that this Privacy Policy will no longer apply once you leave our Website or such applications, and that we are not responsible for the privacy practices of third party sites or applications.  We therefore suggest that you closely examine the respective privacy policies of third party sites and applications to learn how they collect, use, and disclose your personal information.

13. Governing Law

This Privacy Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Quebec and the applicable federal laws of Canada.

14. Addressing Your Inquiries and Concerns

Any individual can address a challenge concerning our compliance with any of the Privacy Principles to our Chief Privacy Officer. We will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices. A customer shall be informed of the outcome of the investigation regarding his or her complaint. Our goal is to protect your privacy and Personal Information. We have designated our Chief Compliance Officer as the Privacy Officer who is responsible for maintaining and implementing our Privacy Policy. Please direct all questions or enquiries about this Privacy Policy to:

Attention:

Chief Compliance Officer
Jean Roy (Managing Partner)
1155 boul Rene Levesque West, suite 2620
Montreal (Quebec) H3B 4S5
Tel.: 514 866-3838 ext. 104

Or by email at jean@davidforest.com

This Privacy Policy was last revised March 2023.

Part II

CASL Compliance

FOREST is committed to reducing the harmful effects of spam and related threats to electronic commerce. The fundamental underlying principle of CASL is that certain commercial activities, such as the sending of commercial electronic messages, may only be carried out with consent.

FOREST complies with CASL and seeks consent as required by CASL before sending any commercial electronic messages.