PERSONAL INFORMATION DISCLOSURE
We value you as a client, and we are committed to protecting the privacy, confidentiality, accuracy and security of your personal information that we collect, use, retain and disclose in our efforts to provide you with superior products and services.
This Personal Information Policy spells out the responsibility of Nour Private Wealth (“we”, “our”, “us”), and your rights as our applicant, client, former client or claimant (“you” or “your”), regarding the collection, use and disclosure of your personal information.
Your Personal Information
Nour Private Wealth understands that trust is an important factor in our relationship, and at Nour Private Wealth, we take this very seriously. Protecting your privacy and the confidentiality of your personal information is a fundamental part of our responsibility to you. Clients of Nour Private Wealth are entitled to a high degree of care in the handling of their confidential information through our policies and procedures as well as state-of-the-art equipment and computer security measures. We ensure that your privacy and the confidentiality of your information are protected. The personal information you provide to Nour Private Wealth (or which the firm collects with you consent) with respect to your account application will be protected and maintained in a client investment file with Nour Private Wealth.
The key components of the firm’s policy are as follows:
The client’s knowledge and consent are required before an employee/agent may collect, use or disclose a client’s personal information.
If any of the personal information collected is sensitive, such as health information, Nour Private Wealth must obtain additional written or oral consent from the client before using or disclosing the information.
Nour Private Wealth shall use care when storing or destroying the client’s personal information to prevent unauthorized access.
Our privacy policy, which includes important definitions and details on how we use your information, is provided below and at [www.Nour Private Wealth.ca](http://www.Nour Private Wealth.ca).
What is Personal Information?
The term “personal information” refers to any information that specifically identifies you, including information such as your home address, telephone numbers, social insurance number, date of birth, assets and/or income information, employment history and credit history.
How are we accountable?
Nour Private Wealth is responsible for your personal information in its possession or custody, including personal information that has been transferred to, or received from, a third party in the course of commercial activities for processing or other purposes for which you have consented to us collecting, using and disclosing your personal information.
Why do we do it?
We collect, use, and disclose personal information to provide you with the investment products and services of Nour Private Wealth.
Specifically, we collect, use and disclose your personal information to:
Verify your identity and correct your personal information;
Determine your eligibility for Nour Private Wealth products and services, and for products that may be of interest to you from business partners with whom we have formed an association, and offer you these products and services, as well as analyze the suitability of our products or services for you.
Accuracy: Nour Private Wealth will keep personal information as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Nour Private Wealth will minimize the possibility that inappropriate information is used to decide about the individual.
Safeguards: Nour Private Wealth will protect personal information using security safeguards appropriate to the information’s sensitivity.
Openness: Nour Private Wealth will be transparent about its policies and procedures regarding the management of personal information. Nour Private Wealth will ensure that individuals can obtain information about the firm’s policies and procedures without undue effort. Nour Private Wealth will make this information available in a form that is generally understandable.
Individual Access: Upon a written request, Nour Private Wealth will inform the individual of the existence, use, and disclosure of their personal information, and the individual will be given access to that information, except where the law requires or permits Nour Private Wealth to deny access.
Questions and Concerns: An individual may direct a challenge regarding compliance with the above principles to Nour Private Wealth’s Chief Privacy Officer.
When produced, updated versions of this Personal Information Policy can be obtained from your account advisor, the compliance department or you can direct any queries about this policy to Nour Private Wealth, Privacy Officer at the telephone, e-mail address, or mailing address listed below. If you have a complaint related to the Personal Information Policy or any of our procedures, contact our Privacy Officer. If your complaint is justified, we will take the necessary steps to resolve the issue, including amending our policies and practices, if necessary. If we are not able to resolve your concern, or if you have any other concerns about Nour Private Wealth’s Personal Information Policy and procedures, you may contact the office of the Privacy Commissioner. Nour Private Wealth Privacy Officer will provide you with this contact information upon request.
Contact Information
For more information, to file a privacy complaint, to make inquiries or to opt out of all or parts of this Policy, please contact us at:
Nour Private Wealth Inc.
2845 Bristol Circle, Oakville, Ontario, L6H 6X5
Attention: Privacy Officer
Tel: 905.845.9090
Fax: 905.845.3115
Email: privacy@npw.ca
BENEFICIAL OWNERSHIP INFORMATION DISCLOSURE
National Instrument 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer
EXPLANATION TO CLIENTS
Based on your instructions, the securities in your account with us are not registered in your name but rather in our name or the name of our carrying broker holding your securities on our behalf. The issuers of the securities in your account may not know the identity of the beneficial owner of these securities.
We are required under securities law to obtain your instructions concerning various matters relating to your holding of securities in your account.SMS Consent and Terms Disclaimer
By providing your mobile number, you consent to receive text messages from NPW. Message frequency may vary. Standard message and data rates may apply. You may opt out at any time by replying STOP or request assistance by replying HELP. Message delivery may depend on your mobile carrier. NPW will not share your mobile number with unaffiliated third parties for their marketing purposes.
Agreement to Terms
You acknowledge that by visiting, accessing and or using this web site that, you agree to be bound by the terms and conditions of its use.
Governing Law and Jurisdiction
This website shall be governed by the laws of the Province of Ontario and the Country of Canada, and you voluntarily agree to submit to the jurisdiction of the courts of the Province of Ontario or any Federal court of Canada.
Website Information and Warranties
The information on this website does not constitute the official version of our disclosure documents and may not always be current. The website and access to it is provided strictly on an “as is” and “as available” basis without any warranties of any kind. The information contained in this website is collected from sources believed to be reliable, but the accuracy and completeness of the information is not guaranteed.
Limitation of Liability
In no event will Nour Private Wealth Inc. assume any responsibility or liability for the accuracy or losses caused by the use or misuse of this website or reliance on the information or content therein, including direct, indirect, special, incidental, consequential, exemplary or punitive.
Jurisdictions of Registration
The information on this website is intended for use by persons who reside in the jurisdictions where Nour Private Wealth Inc. is registered. Currently, we are registered in the following Provinces in Canada:
Alberta
British Columbia
Manitoba
New Brunswick
Nova Scotia
Ontario
Quebec
Prince Edward Island
Saskatchewan
We are members of the Canadian Investor Protection Fund (CIPF) and the Canadian Investment Regulatory Organization (CIRO).
Intellectual Property
Unless otherwise noted, Nour Private Wealth Inc. is either the owner or licensed user of the copyrighted material on this website. The Nour Private Wealth Inc’s name, logo, brand names and all other trademarks are the property of, or licensed to, Nour Private Wealth Inc. and unauthorized use is strictly prohibited.
Not Financial or Legal Advice
The information offered on this website is not intended to provide any specific wealth planning, tax, legal or accounting advice. The information offered on this website is not to be considered an offer to buy, sell or a solicitation of any kind to buy or sell any security, derivative, or any other investment product or service.
Electronic Communications and Security
Without secure encryption, this website is not a secure medium for electronic communications. Confidential use of this website cannot be guaranteed. You there for acknowledge that any confidential information transmitted by a user utilizing this medium may be read and/or copied by unauthorized individuals. Nour Private Wealth Inc. assumes no responsibility or liability for any harm that may occur in connection with any breach or hack that may compromise personal information transmitted through this website. Be advised that trading instructions should not be communicated via email, and if any such instructions are received, they will not be acted on.
Insurance Services are provided in Ontario through Nour Insurance Services Inc., not Nour Private Wealth Inc. The sale of Insurance products by your advisor is based on that advisors Insurance registration through the Financial Services Commission of Ontario.
Use of Cookies
Nour Private Wealth Inc. reserves the right to use cookies on this website. Cookies are small, harmless data files that websites can write to your hard drive when you visit them. A cookie can include a user ID that the site uses to track the pages you visit. Cookies may also be used to enhance your experience on the website, to determine user traffic patterns and for other purposes. Cookies can be removed from your browser at any time by accessing the Safety tab in your browser and deleting your browser history.
User Responsibility and Communications Monitoring
It is the user’s responsibility to take all necessary precautions, including scanning for viruses and other malware. All internet email messages and their attachment received and sent through the facilities of this website and the computers used by all employees, agents and advisors are subject to review by supervisory personnel. Such communications are retained, and we may be required to produce them to our regulatory authorities. All products and services provided by Nour Private Wealth Inc. are subject to the terms and conditions of the applicable agreements governing their use.
The Accessibility for Ontarians with Disabilities Act (AODA) is a law that sets out a process for developing and enforcing accessibility standards. Recognizing the history of discrimination against persons with disabilities in Ontario, the purpose of this Act is to benefit all Ontarians by developing, implementing and enforcing accessibility standards to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises on or before January 1, 2025. To achieve accessibility, the AODA establishes five standards that recognize five areas of daily life:
Customer service standard
Information and communications standard
Transportation standard
Employment standard
The Design of Public Spaces Standard
Together, these standards work to make Ontario more accessible by ensuring that people with disabilities can participate more actively in their communities. Nour Private Wealth Inc. is committed to providing to our clients the highest standard of service possible.
Nour Private Wealth’s commitment is;
To provide our goods and services in a manner that respects the dignity and independence of persons with disabilities;
To provide our goods or services to persons with disabilities and others in an integrated manner to enable a person with a disability to obtain, use or benefit from the goods or services;
To allow our clients with disabilities, as much as is possible, an opportunity equal to that given to others to obtain, use and benefit from the goods or services;
To ensure our policies deal with the use of assistive devices, service animals and support individuals* by persons with disabilities to obtain, use or benefit from Nour Private Wealth’s goods or services or the availability, if any, of other measures which enable them to do so.
When communicating with a person with a disability, Nour Private Wealth shall do so in a manner that considers the person’s disability;
*In situations where confidential or personal information might be discussed, consent will be obtained from the client regarding the sharing of this information with the support individual.
Conflicts of interest—whether actual, potential, or perceived—may arise in any interaction with individuals or organizations. Our relationship with you is no exception. NPW operates as a “retail” and investment firm (or retail investment dealer), offering a range of services and products to retail clients. By definition, this business model exposes us to more potential conflicts of interest than many other types of business activities. For instance, we may sometimes represent both sides of a transaction—the buyer and the seller.
Conflicts of interest generally fall into three categories:
Conflicts between you and NPW
Conflicts between you and other NPW clients
Conflicts between NPW and our related or associated companies
As an investment dealer, we serve as a financial intermediary. In some instances, we may act as the counterparty to your transaction (a “principal” trade) by selling you securities that we own. In other cases, we facilitate a transaction between you and a third party (an “agency” trade) where we do not hold ownership of the securities being traded. Additionally, there may be occasions where one NPW client is trading on the opposite side of your transaction, facilitated by an NPW Advisor.
At NPW, we address and manage conflicts of interest through three primary methods:
Avoidance: We avoid conflicts prohibited by law or those that cannot be effectively managed.
Control: Acceptable conflicts are managed by segregating business functions and restricting internal information sharing.
Disclosure: We provide clear and timely information about conflicts to enable you to independently assess their significance when evaluating our recommendations and actions.
For material conflicts that are unavoidable and reasonably foreseeable, we address them in your best interest and disclose them promptly—either at account opening or as they arise. This disclosure will occur before or when making recommendations or facilitating transactions, allowing you reasonable time to assess the implications.
It is important to note that NPW Advisors and Portfolio Managers cannot solely fulfill their obligations to address material conflicts of interest through disclosure. All material conflicts must be promptly reported to NPW by the Advisor or Portfolio Manager. When we provide disclosure, it will be clear, specific, and meaningful, outlining how the conflict may impact our services.
The following information is intended to help you understand and assess potential or actual conflicts of interest and how we manage them. However, this is not an exhaustive list, as conflicts can vary depending on the circumstances. If you have questions or concerns about conflicts of interest or any other matter, please do not hesitate to ask your NPW Advisor or Portfolio Manager for further explanation or additional details.
We recognize that conflicts of interest can arise and are committed to managing them transparently and in your best interest.
Below, we outline potential conflicts and the steps we take to address them effectively:
We earn compensation from the products and services you purchase from us.
All fees, commissions, and other compensation are disclosed to you in advance so you understand what you are paying.
We offer various pricing options depending on your product or account type, and different products and services may have varying compensation levels.
To reduce conflicts associated with commission-based pricing, we offer alternative pricing structures.
Industry regulations and our firm policies require us to provide only “suitable” investment recommendations.
We may exclude complex products with high commissions from our offerings to avoid unnecessary conflicts.
Under certain circumstances, NPW may deal with you or for you in securities transactions where the issuer of those securities is related or connected to us.
Nour Private Management Inc. (“NPMI”) is an affiliate of NPW and parent company of Goodwood Inc. (“Goodwood”), which is registered as an investment fund manager (“IFM”) under the Securities Act in Ontario, Quebec and Newfoundland & Labrador. NPW is also the sub-advisor for the investment funds managed by Goodwood (the “Funds”) and NPW will have discretionary trading authority over the investment portfolios of the Funds. In addition, NPW will be principally responsible for the marketing and sale of interests in (or units of) the Funds.
As a result of this relationship, the following investment funds are considered both proprietary products and connected issuers to NPW:
Goodwood Fund
Goodwood Capital Fund
Goodwood Milford Fund Trust
Goodwood Milford Fund Limited Partnership
and certain other special purpose limited partnership funds managed by Goodwood Inc.
See also Proprietary Product disclosure below. If NPW does provide advice with respect to the purchase or sale of securities of related issuers or connected issuers, we will (a) disclose and notify you of our relationship to the issuer of such securities; and (b) comply with all applicable requirements under securities legislation.
NPW advisors earn fees from providing investment management services and may at times recommend or cause a client account to invest in investment funds managed or offered by NPW or entities affiliated with NPW (Proprietary Products). This is an inherent conflict of interest since there is a potential risk that NPW or an NPW advisor could put their interests, or the interests of affiliated entities ahead of client interests when making such investment decisions.
There is also a potential conflict that a NPW advisor is only providing clients with access to proprietary products from which NPW or its affiliates earns management, performance and/or advisory fees and is not providing clients with access to a wider universe of non-proprietary products managed by third-party fund managers.
Further, a conflict would exist in instances where the suitability determination conducted by NPW may not consider the larger market of non-proprietary products or whether those products could be better, worse, or equal in meeting the clients’ investment needs and objectives.
As such, NPW will take the following measures to control and avoid conflicts of interest:
1. NPW advisors are compensated based on a fee, charged as a percentage of the total value of the account and are not compensated based on the type of investment held in an account and receive no benefit from recommending proprietary products over non-proprietary products. In addition, NPW and its affiliates will not receive any additional compensation (i.e. no sales commissions payable) from its clients or from the Funds in connection with the distribution of Units of the Funds as selling dealer.
2. NPW advisors can trade in or recommend proprietary products in addition to non-proprietary products and will always conduct Know Your Product (KYP) to assess suitability to ensure that the client’s best interests are placed first and foremost. Proprietary Products are subject to the same due diligence, selection and ongoing monitoring process as non-proprietary products and NPW advisors will only select Proprietary Products if it is determined to be the most suitable for the client when compared against other non-proprietary alternatives. NPW periodically reviews and documents both proprietary and non-proprietary products to ensure suitability and competitive performance.
Certain directors, officers, or significant shareholders of NPW, may hold personal investments in Proprietary Products, aligning their interests with those of clients. Internal policies ensure that client interests are always prioritized.
Fee-based accounts may hold securities or investment funds that include embedded compensation, which may generate revenue for NPW in addition to the management fee paid by clients.
We may also receive compensation from third parties in connection with certain products, such as trailer fees on mutual funds or finder’s fees on private placements.
To avoid double-charging of fees, products that pay trailer fees to the advisor and the firm are coded as non-billable assets and are excluded from the asset base calculation of fee-based accounts. NPW conducts testing every month the exclusion of the non-billable assets from the asset base calculation.
These compensation arrangements are disclosed to you, and securities issuers must include details in offering documents, such as Prospectuses, fund fact sheets, offering memorandums etc.
NPW may be compensated in other ways; this compensation may be a result of business you may do with us, including interest spreads on uninvested cash deposits with NPW, and foreign exchange spreads when you convert currencies.
We may sell you securities that we own (principal trades) and earn a profit.
Each transaction’s role (principal or agent) is indicated on your trade confirmation.
Our website discloses all related parties. If a transaction involves related securities, your trade confirmation will indicate this.
Advisors receive the same commission payout percentage regardless of the product’s originator.
When securities availability is limited, we apply a “fair allocation” policy, especially for managed accounts.
If we provide research on securities of companies with which we have other business relationships, we disclose any potential conflicts of interest in our reports.
Our research and recommendations comply with stringent regulatory and internal standards.
NPW does not currently engage in proprietary trading (trading securities for our account).
If we begin proprietary trading, information barriers will be established to separate corporate trading activities from retail advisory services. As industry regulations require, client trades will always take priority over firm or employee trades.
Some registered individuals, including your NPW Advisor, may participate in outside employment or activities.
These arrangements are carefully reviewed for conflicts of interest and comply with regulatory requirements and internal policies.
Canada has robust securities regulations designed to protect clients and address conflicts of interest. For more information, visit:
The Canadian Securities Administrators (CSA): www.securities-administrators.ca
CIRO: www.ciro.ca
This policy is available on our website at www.nourprivatewealth.com.
If you have any questions or concerns about conflicts of interest, we encourage you to speak with your NPW Advisor or Portfolio Manager. Transparency is key to our commitment to your trust.
How to Make a Complaint
If you have a complaint about an account, investment, service, or representative of Nour Private Wealth, please submit your complaint in writing to our Designated Complaints Officer at:
Name/Title: Dan Godind | Branch Manager
Email: dgodin@npw.ca
Mail: 2845 Bristol Circle, Oakville, Ontario, L6H 6X5
Phone: 905.845.9090
Fax: 905.845.3115
Please include your name, contact information, account number (if applicable), details of your complaint, relevant dates, and any supporting documents.
We will review your complaint in accordance with our complaint-handling procedures and generally provide a written response within 90 days.
If you are not satisfied with our response, or if you do not receive a response within 90 days, you may contact the Ombudsman for Banking Services and Investments (OBSI), a free and independent dispute-resolution service:
Phone: 1-888-451-4519
Email: ombudsman@obsi.ca
Website: obsi.ca
You generally have 180 days from the date you receive our response to bring your complaint to OBSI.
