Privacy Policy

The Stonepay Privacy Policy governs ("Stonepay"). All other Stonepay affiliates, dealings and/or undertakings are governed by their individual privacy policies.

Stonepay's clients include governments, institutions, corporations and individuals. At Stonepay we respect the privacy of our clients and we are committed to keeping your personal information accurate, confidential, secure and private. We have adopted the following privacy policy to ensure that Stonepay continues to meet its commitment to privacy.

In the course of providing these services, Stonepay may consensually collect certain personal information about our clients.

"Personal Information" means information about an identifiable individual client. This may include without limitation, the individual's name, address, age, gender, income, employment status, credit history, debts and liabilities, income, personal preferences and other information about his or her family. Personal information does not include the name, title or business address or telephone number of an employee of an organization.

The Stonepay Privacy Policy is based on, and complies with, Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official web site of the Privacy Commission of Canada at

This privacy policy describes the ten principles that Stonepay follows to ensure that we protect our clients' personal information when we collect, use or disclose it in the course of carrying on commercial activities in Canada or the United States. All of our employees who have access to personal information must adhere to the Stonepay Privacy Policy and related procedures. To this end, Stonepay has appointed a Privacy Officer to ensure compliance by all Stonepay's employees.

This introduction and the following sections, read as a whole, comprise the Stonepay Privacy Policy:

  1. The Ten Principles of Privacy
  2. Application of the Ten Privacy Principles
  3. Questions, Concerns and Complaints


The following ten principles govern our actions as they relate to the use of our clients' personal information:

  • Principle 1 - Accountability
  • Principle 2 - Identifying Purposes
  • Principle 3 - Consent
  • Principle 4 - Limiting Collection
  • Principle 5 - Limiting Use, Disclosure and Retention
  • Principle 6 - Accuracy
  • Principle 7 - Safeguarding Personal Information
  • Principle 8 - Openness
  • Principle 9 - Client Access
  • Principle 10 - Addressing Client Complaints
Principle 1 - Accountability

Stonepay is accountable for all personal information in our possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our clients or employees.

Principle 2 - Identifying Purposes

Stonepay will inform you of the purposes for which it is collecting any personal information, unless otherwise apparent, before or at the time the information is collected.

Principle 3 - Consent

Stonepay will obtain consent from our clients before or when we collect, use or disclose their personal information.

A client's consent can be express, implied, or given through an authorized representative. A client can withdraw consent at any time, with certain exceptions. Stonepay, however, may collect, use or disclose personal information without the client's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.

Principle 4 - Limiting Collection

The information collected from the client will be limited to those details necessary for the purposes identified to the client. Information will be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention

Personal information will only be used or disclosed for the purpose for which it was collected unless the client has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected.
In certain exceptional circumstances, Stonepay may have a legal duty or right to disclose personal information without our clients' knowledge or consent with respect to matters that concern the company's or the public's interest.

Principle 6 - Accuracy

Stonepay will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Clients may have this information amended where it is found to be inaccurate or incomplete.

Principle 7 - Safeguarding Personal Information

Personal information is safeguarded using measures appropriate to the sensitivity of the information.

Principle 8 - Openness

Stonepay will make information available to our clients about the policies and procedures Stonepay uses to manage personal information. Clients have access to this information through our web site, or through alternate means if requested.

Principle 9 - Client Access

Upon written request, a client will be informed of the existence, use and disclosure of their personal information, and will be given access to it. Stonepay will respond to such requests as efficiently as possible. If Stonepay is prohibited from providing such access we will explain the reasons for the lack of access, except where prohibited by law.

Principle 10 - Addressing Client Complaints and Suggestions

Stonepay has policies and procedures to receive, investigate and respond to clients' complaints and questions. Clients may contact the Stonepay Privacy Officer to express any concerns or to request access to their personal information. The contact information for this individual is provided below.


2.1 The Kind Of Information We Collect

Stonepay gathers and uses personal information in order to provide you with the services you have requested or to offer additional services in which you may be interested. Providing us with your personal information is your choice, however, we may not be able to provide you with certain services if you do not provide us with certain information.

The nature of your request will determine the kind of personal information we might ask for.
Information that is typically required to provide you with our services includes:

  • Name,
  • Address,
  • Phone number(s), and
  • Relevant financial information.

If you are applying for credit or investing in any of our funds , you will be asked for specific financial information, including but not limited to investment objectives and relevant financial information.

If there are tax implications related to your financial activities, the federal government requires that we ask for your Social Insurance Number for tax reporting purposes pursuant to the Income Tax Act.

Stonepay may keep a file with your contact history to be used for inquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you.

If you visit Stonepay web sites, we do not collect personally identifiable information about you unless you provide it. All information that you do provide us with is securely maintained and kept strictly confidential.

2.2 How We Use Your Information

At Stonepay we use personal information for three general purposes:

  • To communicate with you in order to provide you with our services or information,
  • To conform to Investment Dealers' Association's regulations for trades, and
  • To make a credit assessment if you are applying for loans.

We will only use personal information for the purpose that we have disclosed to you.
If we want to use your information for a different purpose, we will notify you and ask for your consent first.

2.3 When We May Disclose Your Personal Information

Stonepay is obliged to keep your personal information confidential except under the following circumstances:

  • When Authorized by You,
  • When Required by Law, and
  • When Permitted by Law.
i. When Authorized by You

Many of the services offered by Stonepay require us to obtain personal information about you in order to perform the services we have been engaged to provide. We will use this information to tailor products to meet your needs and objectives. We will always obtain consent from you first, and we will never use the information for purposes other than those we have told you about.

ii. When Required by Law

The type of information we are legally required to disclose usually relates to government tax reporting requirements. However, in some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to request the information.

iii. When Permitted by Law

The legislation has provided certain situations where Stonepay is legally permitted to disclose personal information without your consent. Examples include situations involving the collection of debt in arrears, or suspicion of illegal activities.

2.4 Who We May Share Your Information With
Stonepay Employees

In the course of daily operations, access to sensitive personal information is limited to those employees with a legitimate reason for accessing it. As a condition of their employment, Stonepay employees are required to follow all applicable laws and regulations, including this privacy policy.

Unauthorized use or disclosure of confidential client information by a Stonepay employee is prohibited and may result in disciplinary measures.

ii. Stonepay Affiliates

In order to better meet your needs, we may share some of your personal information with our affiliates. We will only do this with your express consent and you may withdraw this consent at any time. The procedure for withdrawing consent is outlined below under the section "2.8 Opting Out".

Stonepay Affiliates are companies that i) are owned 50% or more by Stonepay; or ii) those companies that Stonepay owns less than 50% and that Stonepay maintains significant influence over the management and operation of the company.

2.5 How We Safeguard Your Information

Stonepay has extensive controls in place to maintain the security of our information and information systems. Client files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.

When you telephone a Stonepay employee to speak about your file, you may be asked for some personally identifying information. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.

2.6 Web Site Security

In order to serve you better, Stonepay may offer clients access to certain information through our web sites. For instance, provides general information about Stonepay and the services we offer.

If you visit Stonepay web sites, we do not collect personally identifiable information about you unless you provide it. All information that you do provide us with is securely maintained and kept strictly confidential.

2.7 Accessing and Amending Your Personal Information

As a client, you have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the personal information held in your file, please make a written request to the Privacy Officer at the address listed below, under "3. Questions, Concerns and Complaints". We will respond to your request as efficiently as possible.

To make a change, please make a similar request in writing to the Privacy Officer.

2.8 Opting Out

In order to provide you with our services, Stonepay will, with your consent, share your personal information with other Stonepay affiliates. Should you not want to receive promotional materials from or have your personal information shared with these companies please contact Stonepay's Privacy Officer at the address, phone number or email address provided in Section 3 below.


If you have any questions, concerns or complaints about your personal information, or about the Stonepay Privacy Policy, please contact our Privacy Officer using the following contact information:
Stonepay's Privacy Officer can be contacted at the following address:

P.O. Box 1 - SUCC. Saint-Charles
Kirkland, Quebec, H9H 0A2

Phone Number: 514-624-5373
Email Address: