Panache Private Wealth

Effective Date: 17 Mar 2026
Last Updated: 17 Mar 2026

Panache Private Wealth (“Panache,” “we,” “us,” or “our”) is committed to protecting the privacy, confidentiality, accuracy, and security of personal information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, protect, and retain personal information through our website and in the course of providing wealth management, financial planning, insurance, and related services in Canada.

We believe privacy should be handled with the same care, clarity, and discipline that guide every aspect of our client relationships.

Scope of this Policy

This Privacy Policy applies to personal information collected through:

• our website;
• contact forms, email, phone, and other communications with us;
• meetings, onboarding materials, and client service interactions;
• subscriptions, event registrations, questionnaires, and other information you choose to provide; and
• technologies used on our website, including cookies and analytics tools, where applicable.

This Privacy Policy does not apply to third-party websites, platforms, or services that may be linked from our website. Those third parties have their own privacy policies and practices.

Our Privacy Commitment

We collect, use, and disclose personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, substantially similar provincial privacy legislation. PIPEDA sets ground rules for how private-sector organizations handle personal information in the course of commercial activity, and its principles include accountability, identifying purposes, consent, limiting collection, safeguards, openness, access, and complaint handling.

What Personal Information We May Collect

Depending on your relationship with us, we may collect personal information such as:

Contact and identity information

• name
• email address
• telephone number
• mailing address
• date of birth
• government-issued identifiers where required by law or regulation

Client and financial information

• investment objectives
• risk tolerance
• income, assets, liabilities, and net worth
• banking and account information
• tax-related information
• insurance-related information
• estate and beneficiary information
• employment and business information
• information needed to satisfy know-your-client, suitability, fraud prevention, and regulatory obligations

Website and technical information

• IP address
• browser type
• device information
• pages visited
• referring URLs
• approximate location inferred from IP
• cookie and analytics data

Communications and preferences

• correspondence with us
• meeting notes
• preferences about services, communications, and consent choices

We collect only the information reasonably necessary for the purposes identified in this Privacy Policy or otherwise disclosed to you at the time of collection. Limiting collection to what is necessary is one of PIPEDA’s core principles.

How We Collect Personal Information

We may collect personal information:

• directly from you;
• from forms you complete on our website;
• from documents and information you provide during inquiries or onboarding;
• through communications by email, telephone, video conference, or in person;
• from cookies, analytics, and similar website technologies;
• from your authorized representatives;
• from financial institutions, insurers, dealers, service providers, or referral sources, where permitted;
• from credit bureaus, identity verification providers, regulators, or public records, where appropriate and lawful.

Whenever practical, we collect personal information directly from you.

Why We Collect, Use, and Disclose Personal Information

We may collect, use, and disclose personal information for purposes such as:

• to respond to inquiries and provide information about our services;
• to determine suitability and provide wealth management, planning, insurance, and related advice;
• to open, maintain, and administer client accounts;
• to verify identity and protect against fraud, unauthorized transactions, error, or other security risks;
• to comply with legal, regulatory, record keeping, audit, reporting, and compliance obligations;
• to communicate with you about your accounts, services, meetings, documents, updates, and service matters;
• to improve our website, services, communications, and client experience;
• to manage our operations, internal reporting, and risk controls;
• to establish, exercise, or defend legal claims; and
• for any other purpose permitted or required by law.

Under PIPEDA, organizations are expected to identify the purposes for collection, use, and disclosure of personal information and make their policies and practices readily available.

Consent

Your knowledge and consent are generally required for the collection, use, or disclosure of your personal information, subject to limited exceptions permitted by law. The OPC’s guidance emphasizes that consent should be meaningful and that privacy practices should be communicated in understandable terms.

By providing personal information to us, communicating with us, using our website, or engaging our services, you consent to our collection, use, and disclosure of your personal information as described in this Privacy Policy, unless a different form of consent is required or obtained.

You may withdraw consent, subject to legal, contractual, regulatory, or operational restrictions and reasonable notice. In some cases, withdrawing consent may limit our ability to provide certain products or services.

When We May Disclose Personal Information

We do not sell personal information. We may disclose personal information only as appropriate for the purposes described in this Privacy Policy, including to:

• our affiliated entities and licensed representatives, where relevant to serving you;
• custodians, dealers, insurers, and product providers;
• service providers who assist with technology, document management, hosting, website operations, analytics, communications, payment processing, compliance, cybersecurity, or administration;
• regulators, self-regulatory organizations, courts, law enforcement, or government authorities where required or permitted by law;
• your professional advisors or authorized representatives, at your direction or with your authorization; and
• a successor organization in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, subject to appropriate safeguards.

We require service providers handling personal information on our behalf to protect it through contractual and other appropriate safeguards.

Website Cookies and Analytics

Our website may use cookies, pixels, log files, and similar technologies to:

• ensure the website functions properly;
• understand website traffic and usage patterns;
• improve website performance and user experience;
• remember user preferences; and
• support security and fraud prevention.

Some cookies are necessary for the operation of the site, while others may support analytics or performance measurement.

You may be able to manage cookie preferences through your browser settings and, where implemented, our website cookie controls. Disabling certain cookies may affect website functionality.

If we use third-party analytics or advertising technologies, additional disclosures should be added here naming those tools and explaining applicable choices.

Third-Party Websites and Platforms

Our website may contain links to third-party websites or services. We are not responsible for the privacy, content, or security practices of those third parties. We encourage you to review their privacy policies before providing personal information.

How We Protect Personal Information

We use administrative, technical, and physical safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. PIPEDA requires organizations to safeguard personal information appropriately, and the OPC also expects organizations to implement procedures, train staff, and maintain complaint-handling processes as part of their privacy program.

These safeguards may include:

• restricted access to personal information on a need-to-know basis;
• confidentiality obligations for employees and service providers;
• secure systems, passwords, encryption, and access controls where appropriate;
• cybersecurity monitoring and risk management practices;
• secure document storage and disposal procedures; and
• privacy and security training for personnel.

No method of transmission over the internet or method of electronic storage is completely secure. While we use reasonable safeguards, we cannot guarantee absolute security.

Retention of Personal Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and to satisfy legal, regulatory, tax, audit, insurance, and business recordkeeping requirements.

When personal information is no longer required, we will securely destroy, delete, anonymize, or de-identify it, as appropriate and permitted by law.

Cross-Border Processing

Personal information may be stored or processed by us or our service providers in Canada or other jurisdictions. When this occurs, the information may be subject to the laws of those jurisdictions and may be accessible to courts, law enforcement, or regulatory authorities in accordance with those laws.

Where personal information is transferred to service providers, we take reasonable steps to ensure comparable protection through contractual and other appropriate measures.

Accuracy

We aim to keep personal information as accurate, complete, and up to date as necessary for the purposes for which it is used. Please notify us if your personal information changes or if you believe our records are inaccurate.

Access and Correction Rights

Subject to limited exceptions under applicable law, you may request access to the personal information we hold about you and request corrections to inaccurate or incomplete information. PIPEDA includes openness and individual access among its core principles.

To make a request, please contact our Privacy Officer using the contact details below. We may need to verify your identity before responding.

Privacy Complaints and Questions

If you have questions about this Privacy Policy, wish to access or correct your personal information, withdraw consent, or make a privacy complaint, please contact our Privacy Officer:

We will investigate complaints and respond within a reasonable time.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada. PIPEDA requires organizations to have procedures to receive and respond to complaints and inquiries.

Children’s Privacy

Our website and services are not intended for children under the age of majority, and we do not knowingly collect personal information directly from children through our website except where provided by a parent, guardian, or authorized representative, or where necessary in connection with legitimate planning or beneficiary-related matters.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or services. The updated version will be posted on this page with a revised “Last Updated” date. Your continued use of our website or services after changes are posted signifies your acceptance of the updated Privacy Policy, to the extent permitted by law.