Privacy Policy

Last updated: September 21, 2023

💡 We protect what is most precious to you

Terry Capital Inc. "Terry", "we", "us" or "our"  acts as an intermediary between the government and you for tax credits and between financial institutions and you for the RDSP. 

Terry is committed to respecting your privacy and protecting your personal information. This is why we have established a personal information management program based on best practices, and have appointed a Privacy Officer.

Throughout the life cycle of the personal information we collect, the following principles govern the way we protect personal information:

  • Protection: Protecting your personal information by implementing an internal governance framework and security measures.
  • Transparency: We take our duty to inform you very seriously. We are therefore committed to respecting our duty to inform by disclosing how we handle your personal information.
  • Respect for your rights: All your rights with regard to the protection of personal information are respected and may be exercised at any time.

The purpose of this Privacy Policy (the "Policy") is to inform you on how Terry collects, uses, discloses, maintains, and protects your personal information.

In order to provide you with quality services, we require access to certain personal information about you. We ensure that our employees manage this information with the necessary discretion and rigour and in compliance with the legal and regulatory requirements in force.

💡 You keep control of your family's information

Personal information

By "personal information" we mean any information about an identifiable individual or that, taken separately or in combination with other data, allows an individual to be identified directly or indirectly. In general, personal information does not include business contact information such as your name, title, business address, or business telephone number.


Terry must obtain your consent before collecting, using or disclosing your personal information.

As a general rule, Terry will obtain the necessary personal information directly from you with your consent, subject to exceptions provided by law.

By providing us with personal information, through our website or web platform (collectively our "Sites"), in an application, by telephone, email, chat or otherwise, you consent to the collection, use and disclosure of your personal information in accordance with this Policy. Please note that your personal information may also be collected through the use of cookies when you visit our Sites.

Terry will not collect, use or disclose personal information without your consent unless it is permitted or required to do so by applicable law. For example, Terry may collect your personal information without your consent for research or statistical purposes, so long as the personal information is de-identified.

When required, Terry may transmit your personal information to regulatory bodies with whom it must collaborate and who govern its activities. For example, Terry may have to proceed without your consent when, for reasons of fraud detection or prevention or law enforcement, seeking the individual's consent would defeat the purpose.

💡 You may withdraw your consent at any time.

Withdrawal of consent and refusal to consent to the collection of personal information

You have the right to refuse the collection, use and disclosure of your personal information. It is your right, if you so desire, to refuse the collection, use and disclosure of your personal information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent to the use of personal information already collected by contacting our Privacy Officer, whose contact information can be found in the "Contact Us" section of this Policy. Refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide you with some of our services, the personal information being necessary for the proper management or administration of your files or the delivery of ongoing services related to your file. In such circumstances, you should be aware that we may be required to close your file or discontinue providing you with a product or service.

Use for Secondary Purposes

Terry may also ask for your consent to use your personal information for secondary purposes, such as conducting market research or populating its databases. If Terry wishes to collect personal information for secondary purposes or purposes other than those described in this Policy, we will obtain your prior consent.

In addition, your consent for secondary purposes may be withdrawn at any time without affecting the provision of our services to you.

💡 We collect only the information we need

What personal information do we collect?

In the course of our interactions with you, we need to collect certain personal information about you. The personal information we collect is necessary to provide you with the services you have requested. This includes but is not limited to

  • Your data and identifying information such as your name, mailing address, e-mail address, telephone number, social insurance number, citizenship, and country of birth in order to identify and correspond with you;
  • Health information, such your use of certain medications, your medical records, medical information, test results, or medical history in order to establish your eligibility for certain tax credits;
  • Financial information, such as the amount of your mortgage, debts, savings, investments, liquid assets and salaries, or in order to get to know you better and offer you advice on investment products that meet your needs;
  • Information about you and your family, such as your occupation, marital status, or the number of children in your family and their ages. We need this information to properly assess investment needs and recommend the right products;
  • Information related to marketing and communication preferences that you have voluntarily provided to us, such as comments or survey responses;
  • Information related to the use of our Sites including technical information on visits or any other information collected through cookies or similar tools;
  • Recruitment information such as CVs, information about your professional or academic background, psychometric test results or any other information relevant to potential recruitment;
  • Any other personal information provided for any of the purposes identified in this Policy.

In addition to this information, we also collect the following data in connection with your use of our Sites:

  • Number of visits;
  • Conversion rate;
  • The average length of your visit;
  • Actions taken on our Sites;
  • The pages consulted during your visit;
  • The type of device used during your visit;
  • The Web browser used during your visit;
  • The IP address used during your visit;
  • The origin of visitors, i.e. the Web page you visited before being redirected to our Sites;
  • The advertising campaign that brought you to our Sites.

It is also possible for us to create a customer account or login using the personal information we collect. Information related to this customer account or identifier is treated as personal information and is subject to the same protections and practices.

💡 Your information allows us to provide you with the service you expect.

Why do we collect your personal information?

Terry collects, uses, and discloses personal information for the purposes identified at the time of collection or as permitted or required by law. This includes, but is not limited to, the following purposes:

  1. To establish and manage our relationship with you, for example:
  2. Determining your eligibility for our products;
  3. Make changes to your investment product;
  4. Offer products through our partnership and referral agreements;
  5. Prevent fraud.
  6. Recommending appropriate products for your needs;
  7. To facilitate the use of our Sites, ensure their relevance, and track usage;
  8. Respond to your requests for information, questions, complaints or comments;
  9. With the prior consent of the person concerned, to enable business development and marketing, in particular, to inform our current and future customers about our new offers;
  10. To carry out development and research to ensure we maintain the highest standards of security and understand our customers' requirements in order to improve our offering;
  11. Recruit staff, process applications, and assess the candidate's profile in relation to the job requirements;
  12. As permitted or required, for any applicable legal or regulatory obligation or provision, including the fight against money laundering and tax evasion as well as the fight against terrorism;
  13. Any other purpose to which you have consented.

How do we collect your personal information?

Terry collects your personal information mainly from you, but also from third parties or by means of cookies or pixels.

  1. From you
    You provide us with personal information directly, for example when you subscribe to savings products, when you contact us or when you click on an advertisement we have placed on a third-party website (e.g. Google, Facebook, etc.).
  2. From a third party
    We may also collect personal information from third parties, or from publicly available records, as permitted by law or if we have obtained the necessary consent. For example, we may collect some of your personal information from your employer, from certain distribution partners for our products and services.
  3. Chat Tool
    In connection with the use of the chat support tool, Terry offers you online services through an advisor who may, where appropriate, request and collect information about you. This information establishes your identity and also allows you to benefit from the services that are available through this tool and that are best suited to your needs.
  4. Telephone call with an advisor
    If required, Terry offers telephone consultations with an advisor who may, if necessary, ask for and collect information about you. This information establishes your identity and also enables you to benefit from the services that are available through this tool and that are best suited to your needs.
  5. Cookies
    Cookies are small data files that are commonly stored on your device when you use Web sites and online services. They are used for the efficient operation of websites and can provide information and help personalize services. Terry collects the personal information provided by cookies.
  6. Pixels
    Web beacons are tiny images that we may place on our Web pages or in our e-mails. They can be used, for example, to anonymously obtain the number of times a particular page has been visited by an Internet user. As their name implies, web beacons are invisible, and any part of our Sites, including the advertising messages displayed on them, may contain web beacons. Unlike cookies, web beacons are not placed on your device when you use a website.
  7. Use for research and development
    Information obtained through the use of cookies or web beacons may also be used for research and development purposes and to improve your experience of our Sites. In such cases, the information is anonymized and used primarily for statistical purposes. We would like to reassure you, however, that no data that could identify you will be used.

💡 We use cookies

Details on the collection, use and communication of data on our Sites (cookies, pixels and other social media functionalities)

As mentioned in the previous section, we may use various tools to improve your Web experience, to better understand our customers' behaviour, and in connection with our marketing strategies. The following section is intended to give you more information on how we use these tools.

Links to websites

It is important to understand that this Policy does not apply to other third-party Websites that may be accessed through links on our Sites. We are not responsible for these third-party sites, their content or access to them. As a result, any personal information you transmit to us through these sites is subject to their privacy policies. It is your responsibility to read their privacy policies to ensure the protection of your personal information.

Cookies and Pixels

By using cookies and web beacons, we are able to offer you advertising that better meets your needs, since it is targeted according to your interests. When you visit our Sites, cookies and web beacons tell us, among other things, which pages you are interested in, so that we can display advertising that matches your interests.  These technologies do not contain any personally identifiable information. They may, however, contain a unique identifier for retargeting purposes. When you click on one of these ads, we may also track the response rate of the campaign.

Terry uses different types of cookies (collectively referred to here):

  • Performance and functionality cookies
    These cookies are not essential to the provision of our services. They help personalize and improve the user experience. For example, they may remember your preferences so you don't have to re-enter information more than once, or they may remember your login details so you don't have to re-enter them each time you use the site. They enable us to understand your behaviour in order to improve our services and our Sites.
  • Cookies for advertising purposes
    They use information about your visit to our Sites, such as the pages you visit or your response to advertisements, to help us provide the best user experience for you.
  • Cookies for security purposes
    These cookies help protect your accounts from unauthorized users. These help maintain session integrity and provide enhanced security, ensuring that unauthorized attempts to access your account are blocked.

Terry mainly uses 2 types of cookies:

  • The session cookie
    This cookie is kept in memory for the duration of your visit to our Sites, after which it is deleted from your device. It identifies you and is subsequently deleted when you leave our Sites.
  • Persistent cookie
    This cookie is stored on your device until it expires and will be retrieved the next time you visit our Sites. Our persistent cookies last for 30 days.

Terry uses different types of cookies, such as performance and functionality cookies, cookies for advertising purposes, and cookies for security purposes. For additional information on how we use cookies, we invite you to consult our Cookie Policy, available by clicking on the cookie image in the lower left-hand corner of your screen.

Please note that the use of cookies only identifies you as a user and does not recognize you by your name or address.

Deactivation of cookies

You can prevent the personalization features of our Sites by disabling cookies on your browser. You can do this by changing the settings on your browser or mobile device.

However, if you choose to refuse cookies, some pages or sections of our Sites may not display properly or some features may not be available.

Do other Websites have access to cookies while you are browsing our Sites?

We sometimes use third-party service providers.

When you access our Sites, either directly or through an advertisement that redirects you to our Sites, a cookie is automatically created on your computer or mobile device. At that time, a Web analysis tool (for example, Google Analytics and Amplitude) and possibly external advertising servers have access to this cookie, which enables us to offer you a better experience on our Sites or, in some cases, to track your activity in order to promote certain of our products. Although a code in the cookie identifies you as a user, it does not recognize you by name or address.

Our service providers may also need to collect your IP address or mobile device identifier when you visit a site. This information may be transmitted to and stored on servers located in Canada or elsewhere, such as the United States. Terry does not combine any information collected by these third parties with information we hold about you. You should be aware, however, that some suppliers may be called upon to communicate the data they collect to third parties in the event of a legal obligation or if they wish to entrust the processing of certain data to third parties. No information that would enable these suppliers to identify you is passed on to them.

Please note that third-party service providers have their own cookies and privacy policies.

Use of Google Analytics 

Terry uses Google Analytics, which is provided by Google Inc. (Google), and Amplitude to analyze the browsing behaviour of the visitors on our Sites, which are tools for analyzing website traffic and usage. The information collected by Google Analytics is used to analyze the use of our Sites and to produce statistical reports on visitor activity. You can get more information about Google Analytics here.

🎯 You determine whether advertising is of interest to you

Targeted advertising

Terry also works with third-party advertising companies, such as Facebook or Google Adwords, which collect and use information about your visits to our Sites in order to present you with advertising that may be of interest to you. Terry does not share any personally identifiable information with these companies.

Please note that our advertising partners and other third parties may also set cookies or web beacons when you click on their advertisements or links to their Web sites or services on our Sites. This Policy does not apply to third-party websites or third-party advertising providers.

You may disable Google Analytics during your browsing by selecting the appropriate settings on your browser or computer tool, as well as your ad settings.

Terry also uses Facebook's Custom Audience feature to target advertising to the interests of current and potential customers. We invite you to check your Facebook privacy settings if you wish to manage your advertising settings. More information is available here.

Please note that even if you choose not to receive ads targeted to your interests, it will still be possible to see ads from Terry. In this case, they will simply not be tailored to your actual needs and may be displayed more frequently.

Social media features

Our services include social media features such as the Facebook share button or interactive mini-programs that run on our Sites. If you use these features, they collect your IP address, the page you visit on our Sites and create a cookie to enable these features to function properly. These features may be hosted by a third party or directly on our Sites. Your interaction with these features is governed by the privacy policy of the company that proves the feature and not by this Policy.

🎯 We work with reputable suppliers.

How do we share your personal information?

From time to time, we may need to share your personal information with agents or other service providers to help us make all of our Sites' functionality available (for example, for purposes of maintenance, analysis, legal requirements, fraud detection, marketing and development). 

These organizations and/or suppliers may be located outside Quebec or in other jurisdictions or countries. They will only have access to personal information that is necessary to perform these tasks on our behalf, and they are required not to disclose or use it for any other purpose.

Where applicable, we ensure through our contractual agreements that these suppliers comply with adequate security measures similar to ours to protect your personal information. In addition, we conduct Privacy Impact Assessments where required by law before disclosing personal information outside the province of Quebec.

As mentioned above, we may also share your personal information when required by law, to enforce compliance or to protect the property or safety of our rights or those of others. We may also need to disclose personal information to comply with a legal obligation (for example, by court order) or to protect our assets (for example, to collect overdue accounts).

In other words, we may disclose your personal information to third parties in the following circumstances:

  • We have obtained your consent to do so;
  • You wish to obtain one of our products. In this case, we transmit the following information to our partners, such as MICA Capital Inc.:
  • ~All the personal information you provided when applying for a policy, as well as associated metadata (including time, date, IP address, browser, and device used).
  • In order to make the functionalities of our Sites available;
  • As required by a securities regulator or other regulatory body;
  • We are required or permitted by law to do so.

🎯 Your family is safe

How do we protect your personal information?

The security and confidentiality of your personal information is important to us. We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the personal information in our possession. To this end, we follow generally accepted industry standards.

The personal information we hold is therefore accessible only to those persons who are authorized to have access to it, and who consult it only when necessary for the performance of their duties.

Our employees, representatives and other stakeholders are committed to protecting your personal information. Our internal procedures clearly define everyone's roles and responsibilities in managing personal information throughout its life cycle.

Security measures

Numerous safeguards are currently in place to protect the personal information we collect. These measures include technological, physical and administrative safeguards. Access to your personal information is also controlled, limiting its use to the purposes specified at the time of collection.

These protection and security measures have been put in place and are kept up to date to prevent:

  • Accidental destruction or destruction not in compliance with the law;
  • Accidental loss;
  • Unauthorized disclosure;
  • Unauthorized modification;
  • unauthorized access; and
  • Illegal processing.

To this end, we restrict access to our offices and computer equipment, train our personnel and require our agents and suppliers of goods and services with access to personal information to sign confidentiality agreements and implement security measures deemed equivalent.

Terry also takes into consideration the protection of our technological platforms, facilities and computer systems.

For example, the following security measures are currently in place at Terry:

Technological measures

  • Two-factor authentication
  • Data encryption
  • Password protection

Physical and administrative measures

  • Limited access by employees, managers, etc., to personal information required for the performance of their duties
  • Monitoring of facilities and computer systems
  • Training for people with access to personal information

If you believe that your personal information has been compromised, or to report a privacy incident, we invite you to contact us using the contact information in the "Contact Us" section of this Policy.

Children's privacy

Our products and Sites are intended for people aged 18 or over. We do not knowingly process personal information of minors, other than that which you voluntarily provide to us, to establish your need for our service. If you believe that we have collected personal information directly from minors, or if you are a parent or legal guardian and believe that your minor child has provided us with personal information, please contact us promptly, using the contact information listed in the "Contact Us" section.

🎯 We are rigorous in the management of your family's information.

How long do we keep your personal information?

We keep your personal information only as long as necessary to fulfill the purposes for which it was collected and to meet our legal obligations.

We keep records of your personal information only as long as it is required for our business relationship, in accordance with our internal document retention policies or legal and regulatory standards. These records will be retained by your mutual fund dealer representative with whom you normally do business, by Terry's Compliance Department or by our service providers.

Strict procedures for the retention of your personal information are followed and we destroy personal information when it is no longer needed for the identified purposes. The length of time we retain your personal information may depend, among other things, on our legal and regulatory obligations, and the time required to protect our rights in the event of recourse.

If you wish to obtain additional information, we invite you to contact us using the coordinates listed in the "Contact Us" section of this Policy.

🎯 You have rights to your personal information.

Destruction of your personal information

As indicated above, we destroy your personal information once the purposes for which it was collected have been fulfilled.

You may also request that your outdated or unused personal information be deleted by submitting a request for the deletion of your personal information. For more information on this subject, we invite you to contact us using the coordinates found in the "Contact Us" section of this Policy.

What are your rights?

Request for access to and correction of your personal information

At any time, you may make a request to consult or rectify the personal information we hold about you.

Such requests are free of charge. Terry may, however, charge a reasonable fee to the person making the request in cases where the latter wishes to obtain a copy of his or her personal information.

When such a request is made, the person making the request must justify his or her identity and prove that he or she is the person concerned by the personal information related to the request or that he or she can have access to it as a representative, for example.

Any request to exercise one of these rights must be made in writing and addressed to Terry's Privacy Officer using the contact information provided below. Terry undertakes to process each request received and to provide you with a written response within thirty (30) days of receipt of the request.

In certain circumstances, your request for access or rectification may be refused. For example, a request for access may be denied if processing the request would result in the disclosure of a third party's personal information and such disclosure would be likely to harm that third party.

If Terry refuses your request, we will provide you with the following information:

  • The reasons for our refusal and the references to the legislation that justify this refusal;
  • Your right to challenge this refusal before the competent regulatory authority; and
  • The applicable deadline for contesting this refusal.

Making a complaint

If you feel that your personal information has been mishandled by Terry, you may file a complaint by contacting our Privacy Officer. We will take the time to analyze your complaint and implement solutions to resolve the situation.

In all cases, your complaint will be handled by our Privacy Officer. Each complaint will be investigated to determine whether it is justified. If the complaint is justified, corrective measures will be implemented by the Terry team to rectify the situation. Terry is committed to keeping you informed throughout the complaint process.

You may also file a complaint with the appropriate regulatory authority. In Quebec, this competent authority is the Commission d'accès à l'information.

Withdrawal of consent

As mentioned in the "Consent" section of this Policy, to the extent permitted by law, you may choose to withdraw your consent to the collection, use or disclosure of your personal information.

You may also withdraw your consent to the use of your personal information for secondary purposes.

For additional information on how to manage your consent, we invite you to consult the "Refusal to collect and withdrawal of consent" section of this Policy.

How to exercise these rights?

Submit your request in writing to the Privacy Officer at the address indicated in the "Contact us" section below.

🎯 We're here for you!

Privacy Officer

Personal Information Management Program

In order to protect your information, we have implemented policies, practices and procedures related to the management of the personal information we hold.

These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as the handling of complaints, information security and data governance. These policies and practices also provide a framework for the operationalization of Privacy Impact Assessments, as well as for the prevention of and response to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer.

The collection of your personal information through our application complies with the requirements of this program.

Roles and responsibilities

Terry's senior management has delegated the management of the privacy program to the Privacy Officer. The Privacy Officer is responsible for the internal management and oversight of Terry's privacy program.

It is the Privacy Officer who approves and implements the privacy policies and procedures, ensures their proper functioning and reports to Terry's senior management on the effectiveness of the program.

The Privacy Officer is also responsible for providing you with the necessary support in the event of a question, complaint or request relating to the protection of personal information.

Contact us

The protection of your personal information is important to us.

You may contact our Privacy Officer in writing using the following coordinates:

Privacy Officer

By e-mail:

By mail, to the attention of the Privacy Officer or Terry Services Financiers inc.

4 Place Ville Marie, Suite 300, Montreal, QC H3B 2E7

If you have any questions or comments about this Policy, or if you wish to request information about your personal information, including requests for assistance, requests for access, requests for rectification and management of your consent, or if you wish to file a complaint about the way in which we manage your personal information, we invite you to contact our Privacy Officer.

Terry would like you to know that we are committed to responding promptly and accurately to all your questions and concerns about the privacy and security of your personal information and our privacy policies and procedures.

Changes and updates to the Policy

The content of our Sites may change at any time. We therefore recommend that you consult our Policy frequently to stay informed about how we handle your personal information. Publication of the amended Policy on our Sites constitutes sufficient notice of such change. In the event of major changes to the Policy, we will inform you. This version of the Policy was last updated on September 21, 2023.

Please note that in the event of any discrepancy(ies), the French version of this Policy shall prevail over the English version.

À titre informatif, en cas de divergence(s), la version française de cette Politique aura préséance à la version anglaise de cette même Politique.