Samara Multi Family Office Inc. (hereinafter referred to as “Samara”) ensures that the personal information you provide to Samara is used only for the purposes for which it is intended, in compliance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Act Respecting the Protection of Personal Information in the Sector Private (the “Quebec Private Sector Act” and, collectively, the “applicable privacy laws”).
The Applicable Privacy Acts notably governs the processing of personal information that individuals provide to companies as part of a commercial relationship.
Under the terms of this legislation we are required to obtain your consent with respect to the collection, use and disclosure of your personal information.
The following text summarizes Samara's current practices regarding the collection, use, and disclosure of our clients' personal information. These practices also apply to the information Samara collects about contacts required to administer your accounts, such as your beneficiaries, proxyholders, trusted contacts, spouse, etc.
If you have any questions or concerns about these policies, please contact the Chief Compliance Officer at confidentialite@samara.ca.
Personal information is information about an identifiable individual or a natural person, including, among other things, your name, contact information, residential address, email address, date of birth, tax identification number, and information regarding your account with Samara. The definition of personal information may vary by jurisdiction. Aggregated and/or anonymized information that cannot be associated with an identifiable individual, directly or indirectly, is not considered personal information.
When you open an account with Samara, we obtain personal information about you that is kept on file in accordance with industry regulations, such as your name, date of birth, social insurance number and address. As part of our Know Your Clients (“KYC”) obligations, Samara also collects financial information, including your assets, debts, income, etc. This information is kept in our records in accordance with industry regulations.
You are not required to provide Samara with your personal information, but if you do not, Samara may not be able to serve you.
The information we collect allows us to identify you, protect you against possible fraud, assess your investment needs, establish and maintain your investment policy, execute certain transactions such as transfers of funds to or from another financial institution, and comply with legal and regulatory requirements. This information is also used to determine your eligibility for certain products and services.
Only authorized employees, authorized third-party service providers and regulatory authorities have access to this information.
If you are an individual, Samara is required to collect, use, and disclose your Social Insurance Number for tax reporting purposes.
Samara may, from time to time, disclose your personal information to external sources such as credit agencies, other financial institutions and other parties who provide services to Samara.
We can also rely on external sources, such as credit rating agencies, to collect personal information about you.
In the event of a change of ownership, sale, amal gamation, liquidation, reorganization or acquisition of Samara, in whole or in part, your personal information may be transferred as part of the transaction.
Samara requires your consent to the collection, use and disclosure of your personal information to administer your account in the normal course of business. Your consent is also required before we may provide your information to our affiliates and any third parties for the purposes described in the paragraphs above.
However, in certain situations, we may collect, use, and disclose your personal information without your consent. These situations include: the collection and use of public information covered by regulations; the disclosure of information to legal advisors for the purpose of obtaining advice; the collection or use of information when it is clearly in your interest to do so, in situations where we cannot obtain your consent in a timely manner; the use and disclosure of information for the purpose of investigating any breach of an agreement or any violation of a law; the disclosure of information for the purpose of recovering any debt you owe us; the use and disclosure of information in an emergency situation threatening your life, health, or safety; the disclosure of information to comply with a subpoena, warrant, or court order, or to otherwise comply with applicable laws, including the requirements of securities regulatory authorities.
You may access the information you have provided to Samara and make corrections to it. We ask that you provide these corrections in writing, addressed to our Privacy Officer indicated below:
Maxim Saint-Amant Lamy
Chief Compliance Officer
Samara Multi-Family Office Inc.
privacy@samara.ca
You can also contact our Privacy Officer if you have any questions or complaints about the way we store or use your personal information.
We may retain your personal information in our files after you cease to be a Samara client, for as long as we need such information or as required by regulatory requirements, i.e. for a period of 7 years following the closure of your account.
Since you have opened an account with Samara, unless you instruct us otherwise in writing to the attention of the Privacy Officer named above, we assume that you consent to the collection, use, and disclosure of your personal information for the purposes set out herein. Although you may refuse to give your consent for any of these purposes and may withdraw such consent at any time, the withdrawal of your consent may, in certain situations, under regulations, prevent us from administering your account.
We have implemented physical, organizational, contractual, and technological security measures to protect your personal information and other data against loss or theft, or against unauthorized access, disclosure, copying, use, or modification, including:
We have taken actions to ensure that only Samara’s employees who need to access your personal information in the course of their duties have access to it.
Your personal information is currently stored in Canada.
Effective date: June 2025