PRIVACY POLICY

Policy Effective Date: 2023-12-13

Introduction

Hawkeye Wealth understands the importance of respecting and safeguarding your privacy and the information you provide to us. That is why we provide you with this privacy statement so you may understand what information we collect, how we collect it, how we use it, and how we may share it with others when you use our website and when you engage with us as a client or potential client. It also outlines your rights when it comes to accessing and deleting any information pertaining to you. If you have any questions about this policy, please get in touch at info@hawkeyewealth.com with attention to our Chief Compliance Officer. You may also call us at (604) 368-2980. 

Please bear in mind that our website contains external links to other websites that are not affiliated or controlled by Hawkeye Wealth, and thus will have different privacy policies and terms of use. The activation of select links on this website may, under certain circumstances, cause the user to leave the Hawkeye Wealth Ltd. website. Hawkeye Wealth Ltd. has not reviewed all the sites linked to the Hawkeye Wealth Ltd. website and accepts no responsibility for the contents thereof or for any products, services or other offers available on them. The inclusion of a link does not imply endorsement by Hawkeye Wealth Ltd. This also applies to websites that offer links to the Hawkeye Wealth Ltd. website. When using those websites, refer to their respective privacy statements. 

What personal information do we collect at Hawkeye Wealth?

Personal Information is any data that can identify an individual, some of which may be sensitive in nature. Hawkeye Wealth collects the following information when dealing with you in a variety of capacities:

• (Full Legal) Name, Address, E-mail Address, Phone Number(s)
• Whether you qualify as an Accredited Investor
• Your website and email behaviour, i.e. links/emails clicked or opened, pages scrolled, forms filled, length of sessions, when you visited our website and where you clicked from, your device and browser type, your IP address and IP location, etc.
• Event attendance and behaviour, i.e. poll answers and questions asked at a webinar, including device information and attentiveness
• Know-Your-Client (KYC) Information
• Financial situation (income, net worth, portfolio breakdown, financing availability, account numbers)
• Personal information (address, occupation, government issued ID, marital status, date of birth, spouse’s date of birth and name, social security number)
• Corporate/Entity Information (certificate of incorporation, EIN, share registry, directorships, trust formation documents, list of trustees/beneficiaries, etc.)
• Other sensitive information (power of attorney, corporate authority, political/influential positions [for self or family members], nature of business).

Why do we collect it?

We are committed to transparency when it comes to the purpose of why we collect your data. The reasons we collect the information above, which information is implicated, and what we use it for, are:

• Provide our investment service (KYC Information, phone, email)
• Marketing and advertising (website, email, event, phone, and email)
• To communicate with you, to provide customer and administrative support, and to notify you of updates to our business that are relevant to you (phone, email)
• Running analytics and to improve our website (device information, IP address, and other web analytics)
• To comply with the law and our compliance obligations, including Anti-Money Laundering regulations, Canada’s privacy and anti-spam laws, and other local, provincial, and federal laws.

Hawkeye Wealth is regulated by a number of securities commissions and other governmental bodies across Canada. At times, Hawkeye Wealth will be obligated to share information collected from our clients for regulatory purposes, including:

• Sales and financial compliance reviews and other regulatory audits,
• Investigation of potential regulatory and statutory violations,
• Regulatory databases,
• Enforcement or disciplinary proceedings,
• Information-sharing with securities regulatory authorities, regulated Marketplaces and law enforcement agencies in any jurisdiction in connection with any of the above.

Please note: Hawkeye Wealth Ltd. must decline to accept or administer an account if you do not consent to collection, use or disclosure of personal information for these purposes. Therefore, by maintaining your account with Hawkeye Wealth Ltd., you have implicitly consented to our collecting, using and disclosing your personal information in the limited manner described above.

How do we collect it?

When collecting personal information, we might do so in an automatic, anonymous manner or by your consent when you interact with us or our website and application forms. Our methods of data collection include:

• Indirectly, such as through cookies and your use of our website and marketing emails (email behaviour, device used, browser used, etc.), much of which is anonymized (your website behaviour and usage which does not identify you until you willingly provide your information to us), much of which cannot necessarily identify you (such as your general IP location, for example your device telling us you logged on from British Columbia) or through referral arrangements when someone refers your information to us under a referral agreement. 
• Directly, through your consent, by filling out our forms on our website (name, phone, email, accreditation), disclosing directly to a Hawkeye Wealth representative in-person, or via other means (telephone, email, video-conferencing, etc.) and by engaging our investment services and thus filling out our Know-Your-Client document.
• Through public sources, such as government websites and other available data that can be accessed directly, such as your employment title from your employing company or the status of a corporation through corporate registries. 
• Through a third-party, where you would have given consent there to have your information provided to us for marketing and advertising purposes (phone, name, email).

We may also place small data files, called “cookies,” in the browser file of your computer’s hard drive. These cookies automatically identify your browser to our server whenever you interact with the website. We use the cookies to record website statistics. Most browsers automatically accept the cookies but you usually can change your browser setting to prevent the acceptance of cookies. Certain web pages may not function properly if you choose not to accept cookies. We make use of Google Analytics when collecting this data and implementing our cookie policy. For more information on how Google handles that data, see here.

Where do we keep it and who has access to or uses it?

• Hawkeye Wealth uses software services that have their cloud and data servers located in the U.S. Thereby your data is susceptible to the Patriot Act and other local/state courts. 
• Hawkeye Wealth keeps backups of our data in local devices that are managed by our employees. These employees abide by strict confidentiality and ethics agreements, signed and reviewed at minimum on an annual basis and revoked immediately upon termination of employment. 
• Individuals only have access to any information that you have provided to us on an as-needed basis; they have to have a lawful and reasonable reason for why they need to access such information, and they must make use of it for the intended purpose of their access.
• Sensitive information, especially regarding clients’ KYC information and investment information, is accessible only by employees registered with the securities commissions, abiding by our code of ethics and conduct and confidentiality terms.

How is it secured?

All of our clients' and prospective clients’ data is processed and stored in third-party softwares that adhere to the highest standards of privacy and security management. These firms all have on-going systems to maintain compliance with industry-wide standards of privacy and security, alongside many other relevant certifications regarding safeguarding of data, payment information, and other sensitive data. Many of these firms are at the forefront of cybersecurity, with internal proprietary code and teams that constantly stress test and update their software, technical, environmental, training, and compliance systems. Other software used by our company does not engage client or sensitive data, unless it can demonstrate the same level of compliance and security as described above. If you would like to learn more about the level and frequency of review we perform on the services we use, please get in touch with our Chief Compliance Officer. 

Internally, our employees are trained and held up to a high standard of diligence when dealing with client data. Our internal processes are in place to ensure access to client data and to our systems is controlled, with regular password updates, access reviews, and our annual cyber security and privacy review. 

Who do we share it with and why?

Hawkeye Wealth will, from time to time, engage third parties in assisting with the operations of our business. These may include software companies from which we host your data, as well as suppliers, investment companies, and other partners. We only share information with individuals and companies that have agreed to abide by this privacy policy or substantially similar confidentiality clauses, and we never sell your information to anyone. Circumstances where we do share your information with another party include:

• A referral party where, with your strict consent, you allowed us to share your contact information with them.
• Issuers, or investment partners, with whom we facilitate your investment and thus we are required to provide them with subscription documents and other relevant information required by law for you to complete your investment.
• Third-party software and data processors, where your information is kept secure and confidential as per our agreements with them.
• Trust companies where, with your express consent, we will provide them with the information necessary to open an account and complete a transaction.
• In case of a merger or acquisition of our company, your information will be shared and transferred to the acquiring firm.
• Other parties from which we have acquired your express consent to share your information with them. 

How long is the information retained before disposal?

For as long as necessary to comply with regulations, including Anti-Money Laundering, Securities Act, and other applicable local and provincial laws. 

Matters relating to Children (under 16) and data subject to General Data Protection Regulation

We do not hold any European data, or data of any children under the age of 16. If you believe we have mistakenly gained access to such data, please contact us and we will promptly delete it. 

Who to contact for questions or concerns regarding your data and this privacy policy?

For any questions regarding our terms and conditions and our privacy policy, please get in touch with our Privacy and Chief Compliance Officer by emailing us at info@hawkeyewealth.com or calling our office line at (604) 368-2980.

What rights do I have with regard to my data? 

As a prospective or current client, you have rights regarding the data that we collect from you, including the ability to correct any incorrect information, access all data we have on you, as well as delete that data, as long as we are not legally obligated to hold such data. To exercise those rights, please use the contact information above to get in touch to submit your request and we will do our best to address your concerns within a reasonable timeframe.

Data Subject Rights under GDPR

As per GDPR, you have the right to:

• Access and obtain a copy of your data on request.
• Require the organization to change incorrect or incomplete data.
• Require the organization to delete or stop processing your data.
• Object to the processing of your data where Hawkeye Wealth is relying on its legitimate interests.
• Withdraw consent at any time where processing is based on consent.
• Data portability for the information you provided to us.
• Lodge complaints with a supervisory authority.

What if this privacy policy changes?

Hawkeye Wealth reserves the right to change this policy and it may be updated periodically. These changes may impact the use of personal information. Accordingly, please review our privacy policy regularly for the most up-to-date version. If there are any changes that materially impact your rights under this policy, we will notify you with a notice by electronic mail.