Privacy Policy
Last updated: April 8, 2026
Protecting your privacy is very important to us. This policy explains how we collect, use, disclose and retain your personal information through our services and our website at www.steadyhand.com. By providing information to us, you consent to our handling of it in accordance with this Policy and as otherwise permitted by applicable law.
1. Personal Information
Personal information means information about an identifiable individual, such as an individual's name and email address, but excludes publicly available directory information and business contact details, where permitted by law.
2. How Steadyhand Collects Personal Information
(a) Personal Information You Specifically Provide
You may voluntarily provide information when completing account applications or using services, including: contact details (name, email, postal address, phone) for general inquiries; comprehensive data for prospective or current clients including contact information, social insurance number, government identification, demographic details, banking information, financial circumstances, and investment knowledge; employment information when applying for positions; and contact details and correspondence sent to Steadyhand.
(b) Automated Collection
Steadyhand uses technologies to automatically collect information about website usage including dates and times that you access the Website or online service, the browsers, operating systems, software, devices and networks you use. The organization employs cookies, web beacons, tokens, pixels or tags to collect information improving products, services, communications and advertising while preventing fraud.
(c) Information from Other Sources
With express consent, personal information may be collected from third parties like accountants, financial planners, or lawyers.
3. How Steadyhand Uses Personal Information
Steadyhand uses personal information for purposes including: providing investment management services, account administration and maintenance; processing portfolio transactions; complying with legal and regulatory obligations; contacting and corresponding with you and designated agents; providing products and services; processing inquiries, requests, and communications; sending information about Steadyhand as permitted by law; maintaining, protecting, and improving services and websites; and protecting and enforcing legal rights, interests, and remedies.
4. How Steadyhand Discloses Personal Information
Personal information is disclosed for relationship and transaction purposes as set out in this Privacy Policy or permitted by applicable law. We do not sell your personal information to third parties.
Personal information may be disclosed to: suppliers and service providers assisting with product and service provision; self-regulatory organizations like the Canadian Investment Regulatory Organization (CIRO) for regulatory purposes; business partners and third parties with your consent or as required by law; and law enforcement or legal authorities as required or authorized by applicable law.
5. Your Right to Withdraw Consent
You may withdraw consent to collection, use, disclosure, and retention at any time, subject to legal and regulatory or contractual restrictions and reasonable notice. Contact the privacy officer using the information provided in Section 18.
6. Advertising/Marketing Messages from Steadyhand
You may elect to receive advertising or marketing messages about Steadyhand. You can request cessation at any time by contacting the Privacy Officer.
7. Audio and Video Recordings
Steadyhand may collect and retain audio recordings of phone calls and video recordings of virtual meetings, with your consent, for compliance, quality monitoring, and legal purposes. Steadyhand will never record a phone call or virtual meeting with you without your consent.
8. Use of Artificial Intelligence and Advanced Technologies
Steadyhand uses artificial intelligence (AI) tools and other advanced technologies to support internal business activities, including research and analysis, investment management, product development, client support functions, and operational efficiency. AI tools are used as decision support tools only and do not operate autonomously or replace human judgment. Investment decisions, advice, portfolio construction, and suitability determinations remain subject to human oversight.
9. Location of Personal Information
Steadyhand will always store your financial information in Canada. Other personal information may be processed, stored, and used at facilities in Canada and the United States. By providing personal information, you consent to transfer to other countries and processing/storage at those facilities.
10. Retention of Personal Information
Personal information is retained for the period reasonably necessary for the purposes set out in this Privacy Policy and to comply with Steadyhand's legal obligations. Information is deleted, disposed of, or depersonalized when no longer required.
11. Protection of Personal Information
Steadyhand uses reasonable safeguards — including administrative, physical and technical security and safeguarding measures — appropriate to information sensitivity to protect against unauthorized access, collection, use, disclosure, deletion, or similar risks.
12. Accuracy and Access to Personal Information
Steadyhand relies on you ensuring provided personal information is as accurate, complete and up to date as necessary. You may request access to personal information and information about collection, use, and disclosure by contacting the Privacy Officer. Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information.
13. Non-Personal Information
Personal information may be used to create and collect non-personal information, including personal information that has been aggregated or otherwise depersonalized. Non-personal information may be used, disclosed, transferred and retained for any purpose.
14. Other Websites and Businesses
Websites and correspondence may include advertisements and links from independent businesses. Steadyhand has no responsibility or liability for, or control over, those other independent businesses, their websites, products or services, or their collection, use, disclosure or retention. This policy does not apply to independent businesses' information handling.
15. Social Media
Information posted on Steadyhand's social media pages is visible to others and can be read, collected, used and disclosed by other persons. Information provided to social media sites is governed by their own privacy policies. You are solely responsible for posted information.
16. Children and Personal Information
Steadyhand does not knowingly collect personal information from children under 13 years of age without the consent of a legal guardian. If discovered, information will be deleted unless guardian consent is provided.
17. Other Matters
Steadyhand may change this policy by posting new versions on the website. Continued dealings signify consent to handling as set out in the changed Privacy Policy. Check the "Last Updated" date and review changes.
18. Contacting Steadyhand
Steadyhand's Privacy Officer may be contacted:
By telephone: 1.888.888.3147 By email: privacyofficer@steadyhand.com By postal mail: Privacy Officer, 130 Adelaide St W, Suite 3100, Toronto, Ontario, Canada, M5H 3P5