1. Introduction
At Clear Skies Investment Management (Clear Skies), your privacy is fundamental to our operations and our values. As a regulated investment firm, we are committed to protecting your personal information in compliance with Quebec’s Act respecting the protection of personal information in the private sector (Law 25), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and applicable securities and anti-money laundering laws.
This Privacy Policy outlines how we collect, use, disclose, and protect your personal information in the context of our investment services, client relationships, website use, and regulatory obligations.
2. Scope
This policy applies to personal information collected through our website (
Home – Clear Skies Investment Management ), client onboarding processes, investor communications, and any other interaction with Clear Skies.
3. Information We Collect
Only authorized employees, authorized third-party service providers and regulatory authorities have access to this information. The information that we collect allows us to identify you, to protect you against possible fraud, to assess your investment needs, and to comply with legal and regulatory requirements. Depending on the nature of your relationship with us, we may collect the following personal information:
From Prospective or Existing Clients:
- Full name, contact details, birth date
- Social Insurance Number or equivalent tax identification
- Banking and investment account information
- Financial goals, risk tolerance, income, and net worth (suitability and KYC purposes)
- Identity verification documents (e.g., driver’s license or passport)
- Employment information
- Investment preferences and transaction history
From Website Users:
- IP address, browser details, usage data
- Cookies and analytics data (see Section 12)
From Job Applicants:
- Resume details, references, background check information (if applicable)
4. Why We Collect Your Information
We collect your personal information to:
- Provide and manage investment management services
- Satisfy legal and regulatory obligations (e.g., KYC, AML, suitability assessments)
- Verify identity and prevent fraud
- Communicate with you and respond to inquiries
- Perform due diligence and maintain accurate client records
- Enhance website functionality and user experience
- Conduct internal analytics and performance reporting
5. Legal Basis for Collection and Use
We collect and use personal information based on:
- Your consent
- Legal obligations under securities and AML laws
- Legitimate interests in operating our investment business
- Contractual necessity (e.g., to fulfill your investment instructions)
6. Disclosure of Personal Information
We may disclose your information to:
- Regulatory Authorities: Including the AMF (Autorité des marchés financiers), CRA, and FINTRAC
- Custodians, Banks, and Transfer Agents: As required to execute transactions and hold assets
- Third-Party Service Providers: For IT, compliance, auditing, cloud hosting, and secure communication platforms
- Legal or Enforcement Bodies: When required by law or in response to lawful requests
- Professional Advisors: Such as lawyers, auditors, and consultants working under confidentiality obligations
- In the event of a change of ownership, sale, amalgamation, liquidation, reorganization or acquisition of Clear Skies, in whole or in part, your personal information may be transferred as part of the transaction.
We never sell your personal information.
7. International Transfers
Your personal information is currently stored electronically in Canada. If need be, it may be stored and processed in any country where we have facilities or in which we use third-party service providers. In the latter case, your personal information may be transferred to countries outside your country of residence, which may have different privacy rules than your country. If these data are outside your country, they are subject to the laws of the country in which they are located and may be disclosed to governments, courts or law enforcement or regulatory agencies of that other country and in accordance with the laws of that other country. However, our practices regarding your personal information will always be governed by this Policy.
8. Your Rights
You have the right to:
- Access the personal information we hold about you
- Request corrections to inaccurate data
- Withdraw your consent (where applicable)
- Request deletion, subject to legal and regulatory retention requirements
- File a complaint with Quebec’s Commission d’accès à l’information or the Office of the Privacy Commissioner of Canada
To exercise these rights, contact us at:
9. Consent
By interacting with us or using our services, you consent to the collection, use, and disclosure of your personal information in accordance with this policy. You may withdraw your consent at any time, subject to legal or contractual limitations.
10. Data Retention
We retain your personal information only as long as necessary to fulfill the purposes for which it was collected and to comply with applicable financial, tax, and regulatory requirements (e.g., AML recordkeeping periods).
11. Safeguard
We take robust measures to protect your personal information:
- Encryption of data in transit and at rest
- Secure document transfer for KYC
- Internal policies on data access and retention
- Staff training and confidentiality agreements
- Regular security assessments and monitoring
12. Cookies and Analytics
Our website uses cookies and similar tracking technologies to collect anonymized usage data and improve user experience. You can manage or disable cookies through your browser settings.
13. Changes to This Privacy Policy
This policy may be updated periodically to reflect changes in legal requirements or business practices. The latest version will always be available on our website. Material changes will be communicated to affected users or clients where appropriate.
14. Contact Us
If you have any questions about this Privacy Policy or your personal information, please contact our Chief Compliance Officer:
