DRAFT — FOR COUNSEL REVIEW — NOT LEGAL ADVICE
Status: Draft template only. Do not publish until reviewed and approved by qualified Canadian counsel. This document is not legal advice and may omit jurisdiction-specific requirements.
Privacy Policy
ICONIQ SERVICES
Operated by 1001738427 ONTARIO INC
Effective date: 2026-09-13
Last updated: 2026-09-13
1. Who we are
ICONIQ SERVICES (“ICONIQ,” “we,” “us,” or “our”) is associated with 1001738427 ONTARIO INC, with an office address at:
100 King Street West, Suite 5700
Toronto, ON M5X 1C7
Canada
Contact / privacy inquiries: info@iconiqservices.ca
(Placeholder for privacy / DPO contact — currently the same as general email unless counsel designates otherwise.)
Website: https://iconiqservices.ca
2. Scope
This Privacy Policy describes how we collect, use, disclose, and protect personal information obtained through our website, email, contact forms, and related business communications. It is intended for visitors and contacts in Canada and reflects practices consistent with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario expectations.
We do not claim establishment under the EU GDPR or UK GDPR solely by virtue of this website. If we later process personal information of individuals in those regions in a way that triggers those laws, we will update this policy and related notices accordingly.
3. Personal information we may collect
Depending on how you interact with us, we may collect:
- Identity & contact data: name, email address, phone number, company, job title, mailing address
- Communication content: messages you send via forms, email, or other channels
- Technical / usage data: IP address, browser type, device type, pages visited, referring URL, approximate location derived from IP, and similar analytics (if enabled)
- Marketing preferences: opt-in / opt-out choices where applicable
We do not require sensitive personal information to use our public website. Please do not submit unnecessary sensitive data through public forms.
4. How we collect information
- Directly from you (contact forms, email, phone, meetings)
- Automatically via cookies, pixels, or similar technologies when you visit our site (if used)
- From publicly available business sources or referrals, where permitted
5. Purposes of use
We use personal information to:
- Respond to inquiries and provide information about our firm
- Administer our website and improve user experience
- Maintain business records and relationship management
- Comply with legal, regulatory, and audit obligations
- Send business communications where permitted (and honour opt-outs)
We do not sell personal information.
6. Investment context (important)
ICONIQ SERVICES is an investment-related business. Contacting us or submitting information through our site does not create an advisory, brokerage, or client relationship. Any investment-related communications are subject to our Investment Disclaimer and applicable securities laws. See: Investment Disclaimer (companion page).
7. Disclosure
We may share personal information with:
- Service providers who assist us (hosting, email, CRM, analytics), under appropriate contractual safeguards
- Professional advisors (legal, accounting) as needed
- Authorities when required by law or to protect rights and safety
- Parties to a corporate transaction (e.g., reorganization), subject to applicable law
We do not disclose personal information for unrelated third-party marketing without appropriate consent where required.
8. Cross-border transfers
Service providers may process data in Canada or other countries. Where information is processed outside Canada, it may be subject to the laws of those jurisdictions. We take reasonable steps to protect personal information consistent with this policy and applicable Canadian privacy law.
9. Retention
We retain personal information only as long as reasonably necessary for the purposes described above, or as required by law, after which we securely delete or anonymize it where practicable.
10. Security
We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information. No method of transmission or storage is completely secure; please contact us if you believe there has been unauthorized access involving your information.
11. Your choices and rights (Canada / PIPEDA-oriented)
Subject to applicable law, you may request to:
- Access personal information we hold about you
- Correct inaccurate or incomplete information
- Withdraw consent for optional processing (where consent is the basis), subject to legal or contractual restrictions
- Ask questions or raise concerns about our privacy practices
To exercise these rights: email info@iconiqservices.ca with the subject line “Privacy Request.” We may need to verify your identity before responding.
You may also contact the Office of the Privacy Commissioner of Canada if you have an unresolved concern: https://www.priv.gc.ca/
12. Cookies and analytics
If our website uses cookies or analytics tools, we will describe essential vs. optional cookies and provide controls where feasible. You can typically manage cookies through your browser settings. Disabling cookies may affect site functionality.
13. Children’s privacy
Our website and services are directed to business and professional audiences, not to children. We do not knowingly collect personal information from individuals under 16. If you believe we have done so, contact us and we will take appropriate steps to delete it.
14. Third-party links
Our site may link to third-party sites (including social platforms). Their privacy practices are their own; we are not responsible for those sites.
15. Changes
We may update this Privacy Policy from time to time. The “Last updated” date will change when we do. Material changes may be highlighted on the website or communicated as appropriate.
16. Contact
ICONIQ SERVICES / 1001738427 ONTARIO INC
100 King Street West, Suite 5700
Toronto, ON M5X 1C7
Email: info@iconiqservices.ca
Phone: +1 416-848-5590
Web: https://iconiqservices.ca
DRAFT — FOR COUNSEL REVIEW — NOT LEGAL ADVICE