Privacy Policy
Enoch Wealth Inc.
Protecting your privacy is fundamental to how we operate. This policy explains how we collect, use, and safeguard your personal information in connection with all of the financial services we provide.
Scope of this policy
Enoch Wealth Inc. is registered with the British Columbia Securities Commission (BCSC) as both an Exempt Market Dealer (EMD) and a Portfolio Manager (PM). This policy applies to all personal information collected in connection with either service:
Exempt Market Dealer (EMD)
We facilitate the purchase and sale of exempt market securities — including private placements, limited partnerships, and other securities distributed under prospectus exemptions pursuant to National Instrument 45-106. As an EMD, we are required to assess each investor's eligibility and suitability before facilitating a trade.
Portfolio Management (PM)
We provide discretionary and non-discretionary investment management services, managing client portfolios in accordance with individual investment policy statements, risk profiles, and objectives under applicable securities legislation.
Where this policy references "our services," it encompasses both streams unless otherwise specified.
Your consent
By engaging us for any of our services, signing a client agreement, completing a subscription agreement or offering memorandum, submitting a Know-Your-Client (KYC) form, or otherwise providing us with personal information, you are indicating your consent to the collection, use, and disclosure of your personal information in the manner described in this policy.
You may withdraw consent at any time, subject to legal and contractual restrictions. Please note that withdrawing consent may affect our ability to continue providing services to you or to fulfill regulatory obligations. To withdraw consent, contact us using the details at the bottom of this page
Information we collect
The information we collect may include any information about you that you give us by engaging us to provide services or in connection with our services or by corresponding with us by phone, e-mail or otherwise. The information may include, but is not limited to your name, address, telephone number, employment information, financial and banking information, investment statements, tax returns, debt statements, copies of wills, powers of attorney, insurance policies, employment benefits, retirement benefits, legal documents and information regarding your investment knowledge, objectives, strategies, needs and values. We request this information to provide our services to you, and to comply with applicable securities and other laws.
It is important that the personal information we hold is accurate and current. Please notify us promptly of any changes to your personal information, particularly changes that may affect your investor eligibility, suitability assessment, or KYC profile.
Website & Technical Data: When you visit our website, our server may automatically log basic, non-personal technical information (such as your browser type and IP address) solely for operational security and system maintenance purposes. We do not use tracking cookies or web analytics to monitor your personal browsing behavior.
Purposes for which we collect your personal information
We generally use your personal information for the following purposes:
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to properly identify you and protect against fraud;
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to provide products and services to you;
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to understand your needs and your eligibility for products and services;
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to establish and maintain a responsible client relationship with you;
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to develop, enhance market products and services and to you;
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to process billing and collection of any fees;
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to conduct surveys and get feedback from you;
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to meet our legal and regulatory requirements;
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to process your inquiries or respond to questions, comments or concerns regarding your portfolio.
Disclosure of your personal information
We are committed to protecting your privacy. Internally, only personnel with a genuine business need — or whose duties require access — are granted access to client personal information, subject to a duty of confidentiality.
We may disclose your personal information to third parties only in the following limited circumstances:
Agents & service providers
We may share your information with custodians, fund administrators, transfer agents, technology providers, and other service providers, but only as reasonably necessary to deliver our services to you.
Issuers & dealers
In our capacity as an EMD, we may share relevant KYC and subscription information with issuers of securities you subscribe to, or with other registered dealers involved in a transaction, as required to complete and document the trade.
Regulatory & government bodies
We are required to report certain information to regulators including the BCSC and FINTRAC under applicable securities and AML legislation. We may also disclose your information to law enforcement or government institutions with lawful authority, or as required by court order.
Legal proceedings
We may disclose your information to comply with a subpoena, warrant, or court order, to comply with court rules regarding production of records, or to our legal counsel as necessary to protect our legal interests.
We do not sell your personal information to third parties.
Location of your personal information
We store and process your personal information in Vancouver, Canada. However, some of our service providers and technology platforms may store or process data outside of Canada, including in the United States. Where your information is transferred outside Canada, it may be subject to the laws of that jurisdiction, which may differ from Canadian privacy law.
We take reasonable steps to ensure that any third parties handling your personal information outside of Canada provide a comparable level of protection.
Access to your personal information
You may request access to your personal information and information about our privacy practices by contacting us at the address indicated below. Subject to certain limited exceptions prescribed by law, you will be given reasonable access to your personal information within a reasonable time, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information.
Security
We take the security of your personal information very seriously and take reasonable organizational, technological and physical measures to protect your personal information against unauthorized access, collection, use, disclosure, copying, modification or disposal, or similar risks.
In the event of a privacy breach that poses a real risk of significant harm to you, we will notify you and the applicable privacy regulator as required by law.
PIPEDA, CASL & applicable law
Our privacy practices are governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the Personal Information Protection Act (PIPA) of British Columbia. We also comply with Canada's Anti-Spam Legislation (CASL) with respect to commercial electronic messages.
We will only send you marketing or promotional communications if you have provided express or implied consent as defined under CASL. You may unsubscribe from commercial electronic messages at any time by contacting us or using the unsubscribe mechanism included in our emails.
Our privacy practices also reflect obligations under the BC Securities Act, National Instrument 31-103 (Registration Requirements, Exemptions and Ongoing Registrant Obligations), NI 45-106 (Prospectus Exemptions), and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
How to contact us
If you wish to obtain further information about our privacy practices or to address any matter concerning this policy, please contact us by email at admin@enochwm.ca or by mail at 350-1200 West 73rd Avenue, Vancouver, BC, V6P6G5.