Privacy policy.

Advisor411 Inc. ("Advisor411," "we," "us," or "our") is a Toronto-based technology company. We maintain a record of the professional information of Canadian financial advisors, drawn from public regulatory records, information that advisors and their firms publish, and licensed data providers, and we use artificial intelligence to generate business intelligence for institutional clients.

This Privacy Policy describes how we collect, use, disclose, and protect personal information in connection with our website, platform, and services. It applies to:

• Visitors to our website (advisor411.com and related domains)
• Business customers and prospective customers who access our platform or receive our services
• Financial advisors whose professional information appears in our platform

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where it applies, Quebec's Act respecting the protection of personal information in the private sector.

Advisor411 Inc. is a corporation incorporated under the Canada Business Corporations Act and operates from Toronto, Ontario. We are responsible for the personal information under our control, and our Privacy Officer is accountable for our compliance with this policy.

For privacy-related inquiries, contact:

3.1 Information About Financial Advisors

We collect professional information about Canadian financial advisors from these sources:

• Public regulatory records, including securities registration records and published disciplinary records
• Professional designation bodies and their public member directories
• Dealer firm websites, including advisor directories and branch locators
• Advisors' own practice and team websites, and their public professional networking profiles
• Licensed business contact data providers

This may include:

• Full name, professional title, and firm affiliation
• Registration status, registration category, sponsoring firm, and registration history
• Whether a regulator has disciplined the advisor or identified a regulatory disclosure, and the published details of that record
• Professional designations and the bodies that issued them
• Business address, phone number, and email address
• Professional biography and practice information that the advisor or their firm publishes
• Links to the advisor's website and professional profiles

We keep a record of the source behind the information we hold.

We do not collect client information, financial account information, personal tax records, government identification numbers, private correspondence, or personal (non-business) contact details.

3.2 Information We Derive From the Record

We use rules and artificial intelligence to generate scores and signals from the information described in Section 3.1, such as distributor attractiveness, fundraising potential, client portability, succession risk, and movement likelihood. These are our estimates. They are not statements made by the advisor or their firm, and we do not add information from any other source to produce them.

3.3 Information About Customers and Platform Users

When organizations access our platform or communicate with us, we collect:

• Contact information for authorized users (name, business email, job title, employer)
• Account credentials and authentication data
• Search queries, saved lists, exports, and other activity within the platform
• Billing and payment information (processed through third-party payment providers)
• Communications between your organization and Advisor411

3.4 Website and Technical Data

When you visit our website or platform, our hosting providers automatically record:

• IP address and approximate geographic location
• Browser type, operating system, and device information
• Pages requested, referring pages, and the date and time of each request

Section 8 explains how we use cookies.

4.1 Advisor Data

We use advisor information to:

• Build and maintain a record of Canadian financial advisors' professional information
• Generate scores and signals for our institutional customers
• Help asset management distribution teams identify and contact advisors about their professional practice
• Help dealer firm recruiters identify and assess prospective advisor candidates
• Keep information accurate by checking it against its sources

We provide advisor information only to institutional customers, for purposes related to advisors' professional activities.

4.2 Customer Data

We use information collected from customers and platform users to:

• Provide, operate, and improve our platform and services
• Manage customer accounts and support requests
• Process payments and maintain billing records
• Send product updates, release notes, and service communications
• Understand how the platform is used so we can improve it
• Comply with legal and regulatory obligations

4.3 Legal Basis

How Canadian privacy law applies depends on the information:

• Business contact information: PIPEDA does not apply to an individual's name, title, and work address, phone, and email when an organization collects, uses, or discloses them solely to communicate or facilitate communication with the individual about their employment, business, or profession (section 4.01). Under Quebec's private sector Act, the collection and confidentiality provisions do not apply to information about the performance of a person's duties within an enterprise, such as their name, title, duties, and work address, email, and phone (section 1). Helping firms reach advisors about their professional practice is the purpose of our platform.
• Registration and disciplinary records: this information comes from registries that regulators maintain for public access. We present it as the regulator publishes it, with its source.
• Other advisor information, including scores and signals: handled as personal information under PIPEDA and the Quebec Act. We limit it to professional information, use it for the purposes in this policy, keep it accurate, protect it, and honour access, correction, and do-not-contact requests.
• Customer and platform user information: processed to provide our services under our agreements with customers, to meet legal obligations, and with consent where we ask for it, such as for optional marketing communications.

5.1 To Customers

Advisor information is disclosed to our institutional customers (asset management firms, dealer firms, and other institutional parties we approve) as the core function of our platform. Customers agree to use advisor data only for lawful business purposes related to advisors' professional activities, to honour do-not-contact flags, and not to use it for harassment, unsolicited bulk communications, or any purpose inconsistent with their agreement with us.

5.2 To Service Providers

We share information with service providers that help us operate, including:

• Cloud hosting and database providers
• AI model providers that power search, chat, and export features
• Email deliverability checking
• Payment processors
• Monitoring, communication, and customer relationship tools

We share only what each provider needs, and providers may use it only to provide services to us.

5.3 Legal and Regulatory Disclosure

We may disclose information when required by law, court order, or regulatory authority, or where necessary to protect our legal rights or the safety of others.

5.4 Business Transactions

In the event of a merger, acquisition, or sale of assets, personal information may be transferred as part of that transaction, subject to equivalent privacy protections.

6.1 Financial Advisors

Any advisor whose information appears in our platform can contact us to:

• Ask what professional information we hold about them and where it came from
• Correct information that is inaccurate or out of date
• Have their profile marked do not contact. We keep the professional record, show the flag in the platform and in every export, and require customers to honour it.
• Ask us to remove information that is not professional information

Quebec residents may also ask us to stop disseminating information about them in the circumstances Quebec law provides.

Send requests to zac@advisor411.com. We respond within 30 days. We check correction requests against our sources and may ask for supporting information.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d'accès à l'information du Québec.

6.2 Platform Users and Customers

Authorized users of our platform may request access to or correction of their account information by contacting us directly or through in-platform settings. Customers seeking deletion of account data should contact us at the address above.

We retain advisor data for as long as necessary to fulfill the purposes described in this policy. We periodically review our records and remove information that is no longer accurate or relevant.

Customer account data is retained for the duration of the customer relationship and for up to seven (7) years afterward to satisfy legal and tax obligations.

Usage logs are retained for up to two (2) years.

We use a small number of cookies and similar technologies to:

• Keep you signed in to the platform and protect your session
• Remember preferences such as display theme and animation settings

We do not use advertising cookies, cross-site tracking, or third-party analytics on our website. You can block cookies in your browser settings, but you will not be able to sign in to the platform without them.

We use reasonable technical and organizational measures to protect personal information against unauthorized access, loss, misuse, or alteration. These include encryption in transit (TLS), provider-managed encryption at rest on production data stores where supported, role-based access controls, and periodic security reviews. Our Security Statement describes these practices in more detail.

No method of transmission or storage is completely secure. In the event of a breach of security safeguards involving personal information that creates a real risk of significant harm, we will notify affected individuals and, where required, regulators, in accordance with applicable law.

Our platform and website may contain links to third-party websites or integrate with third-party tools. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through our platform.

Our primary database is hosted in Canada. Some service providers, including application hosting and AI model providers, process data in the United States. Information processed outside Canada may be accessible to authorities in that country under its laws. We use contractual protections with these providers, consistent with PIPEDA.

Our platform is intended solely for business use by adults. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected such information, we will delete it promptly.

We may update this Privacy Policy from time to time. Material changes will be communicated on our website or by direct notice to active customers. The dates at the top of this policy show when the current version took effect and when it was last updated.

For questions, complaints, or requests relating to this Privacy Policy or our privacy practices, contact: